How Should an Indian Freelancer Set Up Recurring Invoices for a Foreign Retainer Client?

A recurring international invoice is a bill an Indian freelancer issues to a foreign client at fixed intervals for ongoing work under one contract. Each invoice is a separate export of services for GST and a separate entry for FEMA tracking. The schedule repeats, but every invoice needs its own number, date and follow-up.

• GST term: GST calls a long retainer a continuous supply of services. That means services provided continuously or on a recurrent basis under a contract for more than three months with periodic payment obligations (CGST Act, section 2(33)).
• Invoice timing: For continuous supply of services, the invoice is issued on or before the due date of payment when the contract fixes one, and before or at the time of payment when it does not (CGST Act, section 31(5)).
• Export test: Each retainer invoice counts as an export of services only if you are in India, the client and place of supply are outside India, and payment comes in convertible foreign exchange or in rupees where RBI permits (IGST Act, section 2(6)).
• FEMA tracking: For services, the nine-month realisation period runs from the date of each invoice, and the EDF is due within 30 days from the end of the month in which the invoice was raised (FEMA Regulations 3(2) and 5(1)).

The repeat schedule makes the paperwork predictable, so it can be batched each month. For the fields every export invoice needs, see the export invoice format guide and the freelance invoice template for international clients.

A retainer counts as continuous supply of services when the contract covers more than three months and the client has periodic payment obligations, as section 2(33) defines it. Shorter or open-ended arrangements are billed under the ordinary 30-day invoice rule in Rule 47.

You set up recurring invoices by fixing the payment schedule in the contract, filing the LUT for the year, and building one invoice template with an unchanging format. Each cycle you issue a new numbered invoice, then batch the EDF and EDPMS paperwork once a month with your AD bank.

1. Write the payment due date into the retainer contract, for example the 5th of each month. With a fixed due date, the GST invoice is due on or before that date (section 31(5)(a)).
2. If you are GST-registered and want to export without paying IGST, file the LUT in Form GST RFD-11 before the first export invoice of the financial year (Rule 96A(1)). See how to file an LUT on the GST portal.
3. Build a template with your name, address and GSTIN, the client's name and address, the address of delivery, the country of destination and the matching export endorsement (Rule 46).
4. Give each recurring invoice the next consecutive serial number, up to sixteen characters, unique for the financial year (Rule 46(b)). A separate series for one client is allowed, since Rule 46 permits one or multiple series.
5. Describe the service and the period covered on each invoice, such as "Retainer for March 2027", so the client, the bank and the tax officer can match it to the contract.
6. If the client pays a cycle in advance and you are registered, issue a receipt voucher for the advance (section 31(3)(d)) with the particulars in Rule 50.
7. Report the month's invoices in Form GSTR-1 for the tax period. Export invoice details are shown in Table 6A of GSTR-1 (Rule 96A(2)).
8. Submit one EDF to your AD bank covering all invoices raised in the month, within 30 days from the end of that month (Regulation 3(2)(a)). See the EDF form guide.
9. When each payment arrives, match it to its invoice number. For invoices up to ₹10 lakh, you can give your AD bank a declaration that the payment is realised, or send one declaration each quarter for bulk closure (Regulation 4(2)).
10. Keep a simple log of invoice number, date, amount, EDF month and payment date, so you can see any invoice nearing the nine-month realisation limit.

Each recurring invoice cycle needs a tax invoice with the export endorsement, an entry in GSTR-1, a place on the month's EDF and a record of the payment received. If the client pays ahead, a receipt voucher is also issued. The table lists each document and the rule behind it.

Missing recurring invoice deadlines can lead to a GST invoice penalty, tax under the LUT on unpaid invoices, and FEMA follow-up from your AD bank. Because a retainer creates a new invoice every cycle, one missed step can repeat across many months before it is noticed.

• GST penalty: Supplying without an invoice, or issuing an incorrect or false invoice, can attract a penalty of ₹10,000 or the tax evaded, whichever is higher (CGST Act, section 122(1)(i)).
• LUT tax: If payment for an LUT invoice is not received within one year or the FEMA period with any RBI-permitted extension, whichever is later, the tax with interest is payable within fifteen days after that period (Rule 96A(1)(b)).
• Late realisation: Each invoice must be realised within nine months of its date, or twelve months if invoiced or settled in rupees, unless your AD bank allows an extension (Regulation 5(1)). Your AD bank is required to follow up on outstanding proceeds (Regulation 5(2)).
• Future exports: If proceeds stay unrealised for more than one year after the due date or extended date, further exports can only be made against full advance or an irrevocable letter of credit (Regulation 13).
• Open entries: An EDF that is not closed against a payment stays outstanding in EDPMS, and the AD bank follows up for documents (Regulation 18(1)(f)). See EDPMS for service exporters.

If a retainer payment is running late, ask your AD bank for an extension of the realisation period before it expires, giving the reasons (Regulation 5(1), second proviso); see extension of the export realisation period. If an EDF was missed, the AD bank may extend the submission period on a request citing reasons (Regulation 3(2)(c)).

One recurring invoice cycle runs from the payment due date in the contract to the closure of the EDPMS entry. For example, say a writer bills a client in the US USD 1,500 for each month under a 12-month contract, with payment due on the 5th of the next month. Invoice RET-07 for March 2027 is dated 3 April 2027, before the 5 April due date. The April EDF is due within 30 days from 30 April, so by about 30 May 2027. The nine-month realisation period runs from 3 April 2027. These figures and dates are hypothetical.

• Reused numbers: Copying last month's invoice and forgetting to change the serial number, which breaks the rule that each number is unique for the financial year.
• Stale LUT: Continuing to bill under last year's LUT after 1 April, when Rule 96A requires the LUT before export.
• Vague period: Leaving out the month or period the retainer covers, so the bank cannot match a payment to one invoice.
• Bundled payments: Letting the client pay three months in one transfer without telling the bank which invoices it settles, which leaves EDPMS entries open.
• Monthly EDFs missed: Treating the retainer as one export and filing a single EDF, when an EDF is due for each month in which invoices are raised.
• Third-party payer: Getting paid by the client's parent company or an agent without telling the AD bank, which then has to check the bona fides of a third party receipt under Regulation 8.

Every rule, deadline and form on this page is linked to its official source, checked on the dates below.

1. Central Goods and Services Tax Act, 2017: Section 2 (Definitions), Clause (33), continuous supply of services (checked 9 Oct 2026)
2. Central Goods and Services Tax Act, 2017: Section 13 (Time of supply of services), Sub-section (2)(a), (2)(b) and Explanation (ii) (checked 9 Oct 2026)
3. Central Goods and Services Tax Act, 2017: Section 31 (Tax invoice), Sub-sections (2), (3)(d), (5) and (6) (checked 9 Oct 2026)
4. Central Goods and Services Tax Act, 2017: Section 122 (Penalty for certain offences), Sub-section (1), clause (i) and penalty amount (checked 9 Oct 2026)
5. Central Goods and Services Tax Rules, 2017: Rule 46 (Tax invoice), Clause (b) and the export proviso (checked 9 Oct 2026)
6. Central Goods and Services Tax Rules, 2017: Rule 47 (Time limit for issuing tax invoice), Main rule: thirty days from the date of supply of service (checked 9 Oct 2026)
7. Central Goods and Services Tax Rules, 2017: Rule 50 (Receipt voucher), Clauses (a) to (k) (checked 9 Oct 2026)
8. Central Goods and Services Tax Rules, 2017: Rule 53 (Revised tax invoice and credit or debit notes), Sub-rule (1A) (checked 9 Oct 2026)
9. Central Goods and Services Tax Rules, 2017: Rule 96A (Export of goods or services under bond or Letter of Undertaking), Sub-rules (1), (1)(b) and (2) (checked 9 Oct 2026)
10. Integrated Goods and Services Tax Act, 2017: Section 2 (Definitions), Clause (6), export of services (checked 9 Oct 2026)
11. Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB (amended up to 22 September 2026), Regulations 2, 3(2), 4(2), 5(1), 5(2), 6, 8, 10(1), 13 and 18(1)(f) (checked 9 Oct 2026)