Does the 9 months apply to freelancers?

Yes. It applies to every export of services that goes on an EDF, whoever raised the invoice.

What if I invoiced in rupees?

Then the payment has 12 months from the invoice date instead of 9.

Is the 9-month limit the same as the GST one-year limit?

No. The 9 months is RBI’s rule under FEMA. The one year is GST’s condition for exports under an LUT. Both apply.

Export guide

Export payment deadline: 9 months from the invoice

Every export invoice starts a clock. Under RBI's 2026 export rules, the payment has to reach India within 9 months of the invoice date, or 12 months if you invoiced in rupees.

Checked against the rules on 6 October 2026

In short

Foreign-currency invoice: paid within 9 months of its date.
Rupee invoice: paid within 12 months.
₹10 lakh or less: the entry can be closed on your own declaration that it was paid.
GST runs its own clock: under an LUT, payment within one year of the invoice.

The rule

The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 set how long an export can stay unpaid. A notification in January 2026 had allowed 15 months, and 18 for rupee invoices; the amendment of 22 September 2026, FEMA 23(R)/(1)/2026-RB, brought it back to 9 and 12 months.

Your monthly EDF puts each invoice on record with your bank, and it stays open in EDPMS until the payment arrives.

Worked dates

Invoice dated	Invoiced in	Paid into India by
15 October 2026	USD	15 July 2027
31 October 2026	EUR	31 July 2027
30 November 2026	GBP	30 August 2027
31 December 2026	USD	30 September 2027
15 October 2026	INR	15 October 2027

The deadline counts calendar months from the invoice date. When the month it lands in is shorter, it falls on that month's last day: an invoice dated 31 December 2026 has until 30 September 2027.

Small entries: closing on your own declaration

An entry of ₹10 lakh or less can be closed on the exporter's own declaration that it was paid, rather than waiting for the bank to match a remittance to it.

If a client is going to pay late

Talk to your AD bank before the deadline, not after it, and keep the emails and reminders that show you chased the payment. FEMA section 13 allows penalties of up to three times the amount involved, so an invoice left to drift is not a small thing.

The GST clock is different

If you exported under an LUT, rule 96A of the CGST Rules separately expects the payment within one year of the invoice. Miss it and the IGST you did not charge becomes payable, with interest. Track both dates; the FEMA one comes first.

Questions people ask

Does the 9 months apply to freelancers?: Yes. It applies to every export of services that goes on an EDF, whoever raised the invoice.
What if I invoiced in rupees?: Then the payment has 12 months from the invoice date instead of 9.
Is the 9-month limit the same as the GST one-year limit?: No. The 9 months is RBI’s rule under FEMA. The one year is GST’s condition for exports under an LUT. Both apply.

Sources

RBI, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (FEMA 23(R)/2026-RB), and amendment FEMA 23(R)/(1)/2026-RB of 22 September 2026
CGST Rules, 2017: rules 46 and 96A