Your Foreign Client Has 9 Months to Pay Now. What Happens at Month 9, 12 and 21.

Search "export realisation period 2026" and most of what comes back says 15 months. Some of it says 18. It's 9.

The RBI's new FEMA export–import regulations, notified in January, did say 15 months (18 for rupee exports). On 22 September 2026, a week before they took effect, an amendment replaced "fifteen months" with "nine months" and "eighteen months" with "twelve months." Pages written in between were never updated.

Here's what the real number means for an invoice you raise this month.

Not legal or tax advice. This reads Regulations 5 and 13 of the FEMA (Export and Import of Goods and Services) Regulations, 2026 as amended by FEMA 23(R)/(1)/2026-RB, and Rule 96A of the CGST Rules. Confirm your position with your CA.

The rule

Regulation 5(1): the full export value of services must be "realised ... and repatriated by the exporter" within nine months from the date of invoice.

• If the export is invoiced and/or settled in Indian rupees: twelve months.
• Your bank can extend either period if you ask "citing reasons for the delay" and it's satisfied.
• Set-off against payables to the same overseas party counts as realisation, if your bank allows it (Regulation 7).

The clock starts on the invoice date. Not delivery, not the date the client approved the work.

One invoice, followed through

An export invoice dated 15 October 2026, in USD, under an LUT. (New to the 1 October rules? Start with what changed for freelancers.)

Month 9: your bank notices first

Your bank has an open EDPMS entry for that invoice. Regulation 5(2) requires banks to "monitor and follow up" with exporters, so expect contact.

This is the moment to ask for an extension if the money is genuinely coming. The bank decides based on your reasons, so give it something concrete: the client's correspondence, a payment plan, a dispute that's being resolved. Ask before month 9, not after.

If the money isn't coming and the invoice is ₹10 lakh or less, you can ask the bank to write off the unrealised amount on your own declaration (Regulation 6). That route has a GST catch.

Month 12: the GST clock

Rule 96A is the condition attached to your LUT. If you exported services without paying IGST and payment isn't received, you owe the IGST plus interest within 15 days after a deadline.

Since July 2024, that deadline has been "one year, or the period as allowed under the Foreign Exchange Management Act, 1999 ... including any extension of such period as permitted by the Reserve Bank of India, whichever is later," from the invoice date. (Notification 12/2024-CT.)

With FEMA at 9 months, one year is later. So the GST deadline is month 12, three months after FEMA's.

That has a useful consequence. If your bank extends the FEMA period past twelve months, the GST deadline arguably moves with it, because the rule takes the later of the two and counts RBI-permitted extensions. One extension request to your bank may do work on both sides. Get the extension in writing, and have your CA confirm it carries over in your case.

The Commissioner can also allow a further period under Rule 96A directly. Full detail on the GST side: Your foreign client hasn't paid in ten months.

Month 21: the one that affects every other client

Regulation 13: if export proceeds remain unrealised "for a period beyond one year from the due date of realisation or extended period," the exporter "shall undertake further exports only against receipt of full advance or an irrevocable Letter of Credit."

For a services invoice, that's 9 + 12 = month 21 (later if your bank extended the due date).

This is the line to avoid crossing. An open invoice from a client who disappeared can turn into every new client paying 100% upfront. Two ways to stop that happening:

• Get an extension from your bank while there's still a realistic chance of payment.
• Close the entry once there isn't: by write-off on declaration (up to ₹10 lakh) or with reasons (above it).

Rupee invoices

If you invoice a foreign client in INR and the settlement is in INR, FEMA gives you 12 months. Rule 96A's "whichever is later" makes the GST deadline 12 months too. The two clocks line up exactly.

Be careful before switching to rupee invoices for this reason. For GST, an export of services needs payment in convertible foreign exchange, or in rupees only where the RBI permits it. Talk to your CA before agreeing to INR billing with a foreign client.

What the old numbers meant

If you invoiced before 1 October 2026, the period that applied when you raised the invoice still governs it. That period moved more than once in the past year, so if you have older invoices still unpaid, ask your bank which date it's tracking for each.

What changed on 1 October is the expectation. Anyone who planned around "15 months from October" (longer retainers, net-180 terms, invoicing on signature for long projects) should re-plan now.

Payment terms are a compliance setting now

• Invoice when the work is delivered, not on signature. The clock starts on the invoice date.
• Break long projects into milestones. Four invoices give you four later-starting clocks, not one early one.
• Take advances where you can. Remember advances and balances must route through the same bank (Regulation 10(1)). And GST is due on advances on receipt.
• Look at every export invoice older than six months, once a month. That's three months before the bank's deadline, and the last comfortable time to chase.

Where Mavoin fits

None of these deadlines arrive with a notification. Mavoin tracks the invoice date and paid status of every export invoice and shows what's outstanding in INR, so a seven-month-old unpaid invoice is something you see, not something your bank tells you about. ₹199/month, 30-day trial, no card.

Start your 30-day trial, or date your next invoice properly with the free export invoice generator.

Mavoin is not a Chartered Accountant service. Verify FEMA and GST specifics with your CA.