Exporting services from India: GST, payments and paperwork

This guide is for businesses and professionals in India who supply services to clients abroad, such as software, design, consulting, BPO, engineering or tourism services. It covers when a service counts as an export under GST, how to get paid, the paperwork that changed on 1 October 2026 and which incentives still apply.

When is a service an export under GST?

Section 2(6) of the IGST Act treats a supply of services as an export only if all five conditions are met:

1. the supplier is located in India;
2. the recipient is located outside India;
3. the place of supply is outside India;
4. you receive payment in convertible foreign exchange, or in Indian rupees where the RBI permits it;
5. you and the recipient are not merely establishments of the same person, such as your own branch or head office abroad.

The place of supply test catches people out. The general rule in section 13 of the IGST Act is the recipient's location, but there are exceptions. Services performed on goods that are physically in India, services directly related to land or buildings in India, and some event-related services can have their place of supply in India even when the client is abroad. Those are not exports.

Intermediary services, such as arranging supplies between a foreign buyer and a foreign seller for a commission, used to have their place of supply in India under section 13(8)(b). The Finance Act, 2026 omitted that clause with effect from 30 March 2026, so these services now follow the general rule and can qualify as exports if the other conditions are met. Ask your adviser how this applies to invoices that straddle that date.

GST: register, file an LUT, claim refunds

A supplier of services only may be exempt from GST registration below the turnover threshold, but you need a GSTIN to file a Letter of Undertaking and claim refunds, so most regular exporters register. File the LUT (form GST RFD-11) on the GST portal for each financial year and you can invoice without IGST. Mark each invoice as a supply for export under LUT without payment of IGST.

Under rule 96A of the CGST Rules, if payment for an export of services is not received within one year of the invoice, or the period allowed under FEMA if that is later, you must pay the IGST with interest. To get back unused input tax credit, file form RFD-01, attaching statement 3 with the bank realisation certificate or foreign inward remittance certificate for each invoice. The time limit is two years from the relevant date, which for services is generally the date you receive payment, or the invoice date if you were paid in advance. See GST for exporters.

Getting paid

• Use a bank that is an authorised dealer in foreign exchange and tell it the correct purpose code for the service, so the inward remittance is recorded as an export receipt.
• Rupee payments count only where RBI allows them, for example through a Special Rupee Vostro Account under RBI's framework for settling trade in rupees. Confirm with your bank before agreeing to be paid in rupees.
• Your bank gives you a foreign inward remittance certificate or advice (FIRC or FIRA) for each receipt, and the realisation data is sent to DGFT's e-BRC system, where you can view the electronic bank realisation certificate. You need these for GST refunds and any DGFT benefit.

Under the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, in force from 1 October 2026 as amended by RBI on 22 September 2026, you must realise the full value of a services export within nine months from the invoice date, or 12 months where the export is invoiced or settled in rupees. If a client is late, talk to your bank before the deadline about an extension.

EDF replaces SOFTEX from 1 October 2026

Under the old rules, software exporters filed SOFTEX forms certified by Software Technology Parks of India (STPI) or the SEZ authorities. Under the 2026 regulations, exports of services, including software, are declared in an Export Declaration Form (EDF) through your bank within 30 days from the end of the month in which you raise the invoice. One EDF can cover a month's invoices to one or more clients. For software, your bank can certify the declaration; STPI and SEZ certification remain available but are no longer the only route. Ask your bank how it wants EDFs submitted, and ask STPI or your bank how SOFTEX forms for invoices raised before 1 October 2026 should be completed.

Which incentives apply now

• The Service Exports from India Scheme (SEIS) has ended, and no general reward scheme for services has replaced it.
• RoDTEP, duty drawback and RoSCTL are for exports of goods. The Niryat Protsahan interest subvention under the Export Promotion Mission is also built around a list of goods tariff lines.
• Zero-rating under GST is the main financial benefit: you export without tax and recover your input tax credit.
• The Services Export Promotion Council (SEPC) issues RCMCs to services exporters and runs trade promotion activity, and units in SEZs or under the STPI scheme have their own benefits. Check with SEPC or the relevant authority what you are eligible for.

Watch out for

• Billing a foreign client for work on goods that are in India and treating it as an export.
• Payments routed through a third party in India, which may not meet the foreign exchange condition.
• Missing the monthly EDF deadline now that SOFTEX has gone.
• No FIRC or e-BRC for a receipt, which holds up the RFD-01 refund.
• Invoicing your own overseas branch and claiming export status.

Related on Exportsmitra

• GST for exporters: LUT, zero-rating and refunds
• e-BRC: the electronic bank realisation certificate
• Export proceeds: realisation deadlines, EDPMS and extensions
• Managing currency risk: forwards, options and PCFC

Sources

• CBIC: IGST Act (sections 2(6) and 13), CGST Rules 89 and 96A
• Goods and Services Tax Network: GST portal
• Grant Thornton Bharat: GST on intermediary services after the Finance Act, 2026
• Reserve Bank of India: FEMA notifications, including the Export and Import of Goods and Services Regulations, 2026
• Summary of RBI notification of 22 September 2026 amending the realisation period (secondary source)
• iSPIRT ProductNation: EDF replaces SOFTEX from 1 October 2026
• Directorate General of Foreign Trade: common digital platform (e-BRC)

Last checked 1 October 2026. Rules change: confirm with your bank and your GST practitioner before you act.