Being paid by foreign clients through a payment platform does not change what an Indian service exporter has to prove. For GST, the supply is an export only if payment is received in convertible foreign exchange, or in rupees where RBI permits, and a refund claim needs a remittance certificate against each invoice. For FEMA, the export value must be realised and repatriated to India within the permitted period, and the bank must be able to close each export entry. Platforms make collection easy. They do not, by themselves, produce a trail that ties each rupee received in India to an export invoice. Building that trail is the exporter's job.
This post covers what the rules require, what a cross-border payment aggregator must provide under RBI's directions, and the gaps to watch.
What the law needs to see
GST. Under section 2(6)(iv) of the IGST Act, receipt in convertible foreign exchange, or in rupees where RBI permits, is a condition of an export of services. For a refund of input tax credit on exports, Rule 89(2) of the CGST Rules requires a statement of export invoices with the relevant Bank Realisation Certificates or Foreign Inward Remittance Certificates.
FEMA. From 1 October 2026, the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 apply. Under Regulation 5, as amended, the full export value of services must be realised and repatriated within nine months from the invoice date, or twelve months for rupee-invoiced exports. Under Regulation 3(2), an Export Declaration Form must be filed with the authorised dealer bank within 30 days from the end of the month in which the invoice is raised, or, for services other than software, on or before the date payment is received. The bank records it in its export monitoring system, EDPMS, and closes it when the payment arrives.
Income tax and audit. Receipts are matched to invoices, exchange differences are calculated from them, and they are tested in audit.
What RBI requires of cross-border payment aggregators
A platform that handles cross-border payments for Indian exporters may operate as, or through, a payment aggregator – cross border (PA-CB) regulated by RBI. The Reserve Bank of India (Regulation of Payment Aggregators) Directions, 2025, issued on 15 September 2025, set out several rules relevant to exporters:
- Transaction limit: the maximum value per PA-CB transaction is ₹25 lakh, for inward and outward transactions (paragraph 11(d)).
- Information for closing export entries: the PA-CB must provide to the exporter's authorised dealer bank the documents or information the exporter needs to close the corresponding export entry in EDPMS (paragraph 11(h)).
- Collection accounts: inward funds are held in an Inward Collection Account with an authorised dealer bank, separately from outward funds (paragraph 16).
- Settlement terms: the timeline for crediting the merchant is set in the PA-merchant agreement, which must state it transparently (paragraph 16, Table 1).
- Merchant due diligence: full KYC applies, with a simplified alternative process for small merchants, defined by an annual turnover or export turnover threshold (paragraph 13).
Platforms differ in how they are authorised and how they route funds. Check how your platform is authorised and which bank credits the funds in India. That bank will close your export entries and issue the remittance documents.
The trail to keep for each payment
For every payment received through a platform, keep the following together, by invoice:
- The export invoice, in the agreed currency, with the GST endorsement for exports under a Letter of Undertaking.
- The platform's transaction record, showing the client, the gross amount, the platform fee and the net amount.
- The inward remittance document issued when the funds were credited in India, from the platform or its bank. It should show the remitter, the amount, the date and the purpose code for the service.
- The payout statement, where the platform pays out several transactions in one transfer, with a breakdown to the invoices it covers.
- The e-BRC, self-certified on the DGFT portal against the bank's inward remittance message.
- The EDF reference for the month of the invoice, and confirmation that the bank has closed the entry.
Where the gaps appear
1. Money left on the platform. FEMA requires export value to be realised and repatriated. A balance held in a platform account outside India has been received, but not yet repatriated. Withdraw to India regularly, well inside the realisation period. If a balance is held abroad, keep a clear record of which invoices it relates to.
2. Consolidated payouts. A single transfer to India that covers twenty client payments, less fees, cannot be tied to invoices without a breakdown. Download the payout breakdown every time, and keep it with the remittance document.
3. Fees deducted before the money reaches India. The platform fee is a cost of the business. Record the gross invoice value as income and the fee as an expense, rather than netting them. If it is charged by an Indian entity with GST, it is an ordinary domestic purchase. If it is charged by an entity outside India, settle its GST treatment as an imported service before filing GSTR-3B.
4. Purpose codes. Payments recorded under a purpose code for personal transfers, or for something other than the service supplied, weaken the remittance as evidence of an export. Set the correct purpose code with the platform, and check each remittance document.
5. The ₹25 lakh per-transaction limit. An invoice above ₹25 lakh cannot be collected through a PA-CB in a single transaction. Agree an alternative route, such as a direct bank transfer, for high-value clients.
6. Currency conversion and timing. A platform may convert currency at its own rate, on a later date than the client's payment. Record exchange differences explicitly in the books. Use the rate required for GST valuation, under Rule 34(2) of the CGST Rules, for the date of the time of supply.
A monthly routine
- Reconcile platform transactions to invoices, client by client.
- Withdraw balances to India and reconcile payouts to transactions.
- File the month's EDF from the same invoice list used for GSTR-1.
- Collect remittance documents and self-certify e-BRCs for the month's receipts.
- Review open export entries against the nine-month realisation deadline.
Where this fits
The evidence described here is the same trail any service exporter needs. Platforms just add a layer between the client and the bank. See FIRC and e-BRC: the paper trail your service exports need and the Export Declaration Form for services.
Wissen Solutions reconciles platform receipts to export invoices and maintains GST and FEMA evidence for service exporters through our GST, income tax and TDS return filing services.
Sources (checked 26 October 2026)
- RBI: Reserve Bank of India (Regulation of Payment Aggregators) Directions, 2025, RBI/DPSS/2025-26/141 dated 15.09.2025: paragraphs 11, 13 and 16
- RBI: Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB, as amended: Regulations 3 and 5
- RBI: Notification No. FEMA 23(R)/(1)/2026-RB dated 22.09.2026: nine and twelve months in Regulation 5
- CBIC Circular No. 37/11/2018-GST: BRC/FIRC for export of services refunds
- DGFT: eBRC services: IRM-based self-certified e-BRC, Trade Notice No. 33/2023-24 dated 10.11.2023
- Notification No. 10/2017-Integrated Tax (Rate): reverse charge on import of services