You Can Now Write Off a Small Unpaid Export Invoice on Your Own Word. GST Still Wants Its Money.

The most useful line in the RBI's new export rules for freelancers isn't the EDF or the deadline. It's a threshold: ₹10 lakh per invoice.

Below it, two things that used to need paperwork, justification and sometimes the RBI can now be done on your own declaration. One is closing an entry when you've been paid. The other is writing off an invoice you'll never be paid for.

Most freelance export invoices sit well under ₹10 lakh. So for most freelancers, this is how the new system will actually feel day to day.

There's one trap in it, and it's on the GST side.

Not legal or tax advice. This reads Regulations 4(2) and 6 of the FEMA (Export and Import of Goods and Services) Regulations, 2026 and Rule 96A of the CGST Rules. Your bank's policy and your CA's view of your facts come first.

Route 1: closing entries when you've been paid

Every export invoice you declare on an EDF becomes an open entry in EDPMS, the RBI's monitoring system. Normally your bank closes it when it matches an incoming payment to the invoice.

Matching doesn't always work. A client pays two invoices in one transfer. A platform nets off its fee. Bank charges shave the amount. The FX conversion leaves a small gap. Any of these can leave an entry open even though you've been paid.

Regulation 4(2), first proviso: where an invoice is up to ₹10 lakh (or the equivalent in foreign currency), the EDPMS entry "may be closed based on a declaration from the exporter to the effect that the payment against the shipping bill / invoice has been realised either in full or otherwise."

And: "such declaration may be submitted by an exporter to the Authorised Dealer on a quarterly basis for bulk closure."

So the practical routine is one declaration a quarter listing the invoices that have been paid, and your bank closes the lot.

Route 2: writing off what will never be paid

Regulation 6 lets your bank reduce the export value it expects you to realise, including down to zero, if you give reasons it accepts.

Its second proviso: where the export value is up to ₹10 lakh per invoice, the reduction "(including non-realisation of full export value) may be permitted based on a declaration from the exporter."

That's a write-off on your own word. A client who disappeared owing a few thousand dollars: you declare it unrealised, the bank reduces the expected value, the entry closes, and you're no longer heading towards the month-21 restriction where every future export has to be paid upfront.

Above ₹10 lakh, the route still exists. You just need reasons the bank accepts.

The trap: FEMA closing the entry doesn't touch GST

If you exported that service under an LUT without charging IGST, Rule 96A attached a condition: if payment isn't received in convertible foreign exchange within a year (or the FEMA period, if later), you pay the IGST plus interest within 15 days.

A FEMA write-off doesn't change that. Your bank has agreed the money won't come. That's precisely the condition Rule 96A is about. The bank's EDPMS entry is closed, the GST liability isn't, and nothing in either system tells the other.

Worked through, for an invoice dated 15 October 2026:

The write-off is the right call on the FEMA side. It protects your ability to keep exporting normally. It just isn't the end of the matter.

What to do about the GST side: Your foreign client hasn't paid in ten months. Two clocks are running.

When to use which

Is a declaration-only route risky?

It's a declaration. It should be true, and you should be able to back it up if asked. Keep, for each invoice you declare:

• The invoice and the EDF it was declared on
• The FIRA for every payment received against it
• For write-offs: your chase emails and anything showing why payment won't come

Banks also have to publish their policy on adjustments, write-offs and extensions (Regulation 19). Read your bank's version before you send your first declaration.

The import side

The same ₹10 lakh rule applies in reverse. If you pay foreign contractors or vendors by wire, those payments create IDPMS entries, and up to ₹10 lakh per invoice they can be closed on your declaration, quarterly in bulk. (Your GST obligations on those payments are separate: reverse charge on foreign services.)

Where Mavoin fits

A quarterly closure declaration is a list: which export invoices were paid, when, and how much arrived. Mavoin tracks paid and outstanding status on every export invoice in its currency and in INR, and exports the list as CSV, so the declaration is a filter, not a reconstruction. ₹199/month, 30-day trial, no card.

Start your 30-day trial.

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