FIRC and eBRC for Export of Services from India in 2026

Written by CA Nandini, Krystal7 Consultants. Last updated 2 October 2026.

A FIRC (Foreign Inward Remittance Certificate) is a bank's certificate that foreign currency reached your Indian account, with the sender, amount, date and purpose code. An eBRC (electronic Bank Realisation Certificate) comes from the DGFT portal. The exporter self certifies it by matching the bank's Inward Remittance Message to an invoice. GST rule 89(2)(c) accepts either one as proof for a refund on export of services.

This page explains both documents, how to get them, and where each one is used. It also covers the FEMA export rules that started on 1 Oct 2026, the GST refund link, and fixes when a certificate is missing.

What is a FIRC?

A FIRC is a certificate your authorised dealer (AD) bank issues for a foreign currency credit to your account. It shows the remitter, the amount in foreign currency, the rupee amount credited, the date and the purpose code. RBI's export directions prescribe no format for it. Each bank issues it on request, in its own format.

FIRC is short for Foreign Inward Remittance Certificate. Many banks now send a Foreign Inward Remittance Advice (FIRA) instead. A FIRA is an advice of credit, often emailed when the money lands. A FIRC is a signed certificate, often issued only when you ask. In practice, banks and refund officers accept both if they carry the same details.

The RBI Master Direction on Export of Goods and Services applied until 30 Sep 2026. It told AD banks to report the electronic FIRC to the Export Data Processing and Monitoring System (EDPMS) "wherever such FIRCs are issued against inward remittances". That wording tells you a FIRC was never automatic. The directions in force from 1 Oct 2026 (A.P. (DIR Series) Circular No. 20 of 16 Jan 2026) do not mention the FIRC at all. You still have to ask for one, or download it from net banking.

Share capital needs one too. RBI's FIRMS user manual lists "FIRC and KYC of the foreign investor" as FC-GPR attachments for money received through banks. So a foreign owned company needs a FIRC for its share capital and an eBRC or FIRC for its export income. Our guide on FC-GPR filing within 30 days covers the investment side.

Term	Full form	Who issues it	What it proves
FIRC	Foreign Inward Remittance Certificate	AD bank, on request	Foreign currency was credited to your account
FIRA	Foreign Inward Remittance Advice	AD bank or payment platform, usually automatic	Same facts as a FIRC, as an advice of credit
IRM	Inward Remittance Message	AD bank, sent to the DGFT system	A trade receipt exists and is linked to your IEC
eBRC	electronic Bank Realisation Certificate	DGFT portal, self certified by the exporter	A receipt was matched to a shipping bill or invoice
EDF	Export Declaration Form	Exporter, filed with the AD bank (services)	The full export value was declared under FEMA
EDPMS	Export Data Processing and Monitoring System	RBI system run through AD banks	Tracks each export until it is realised

What is an eBRC and how is it different from a FIRC?

An eBRC is an electronic certificate on the DGFT portal that links a specific inward remittance to a specific export invoice or shipping bill. A FIRC only proves money arrived. The eBRC adds the link to the export. DGFT's eBRC FAQs (version 1.1, August 2025) describe it as confirmation that the exporter received payment against an export of goods or services.

The eBRC system has two generations.

Under RBI A.P. (DIR Series) Circular No. 04 of 15 Sep 2017, AD banks generated eBRCs only from EDPMS data from 16 Oct 2017.

DGFT then launched self certification through Trade Notice No. 33/2023-24 of 10 Nov 2023. Banks now push an IRM for each trade receipt to DGFT. The exporter logs in, maps the IRM to an invoice and generates the eBRC.

DGFT FAQ 21 answers the comparison in one line: the electronic FIRC and the eBRC are different systems. A bank FIRC and a DGFT eBRC can both exist for the same receipt. Neither replaces the other in every context.

Point	FIRC	eBRC
Issued by	Your AD bank	DGFT portal, after the exporter maps the IRM
Needs an IEC	No	Yes, the IEC must be linked on the DGFT portal
Linked to an invoice	No	Yes, to an invoice number or shipping bill
Covers capital receipts (share money, loans)	Yes	No, only trade receipts
Format	Bank's own	Appendix 2U of the Handbook of Procedures, 2023
Can be cancelled	Ask the bank	Exporter can cancel within 120 days of generation (DGFT FAQ 80)
Accepted for GST refund under rule 89(2)(c)	Yes	Yes
Used for FTP benefits	Usually not enough	Yes
Typical cost	Bank's schedule of charges	DGFT FAQs mention no fee

When do service exporters need a FIRC or eBRC?

You need one of them whenever someone asks you to prove that an export of services was paid in foreign exchange. That happens in four places. GST asks at refund time. FEMA asks through your bank's EDPMS tracking. DGFT asks when you claim a Foreign Trade Policy benefit. Lenders and auditors ask during due diligence.

GST is the most common trigger. Section 2(6) of the IGST Act, 2017 treats a supply as an export of services only if five conditions hold. One of them is that the supplier receives payment in convertible foreign exchange, or in Indian rupees where RBI permits. If that condition fails, the supply is not an export, and it is not zero rated. The FIRC or eBRC is how you show the condition was met. Our guide on GST on export of services walks through all five conditions.

Situation	Document usually asked for	Rule behind it
Refund of unused ITC on exports under LUT	BRC or FIRC per invoice, in Statement 3 of RFD-01	CGST Rules rule 89(2)(c)
Refund of IGST paid on export of services	BRC or FIRC per invoice, in Statement 2 of RFD-01	CGST Rules rule 89(2)(c); Circular 125/44/2019-GST
Showing a supply qualifies as export	Proof of receipt in convertible foreign exchange	IGST Act section 2(6)(iv)
Closing the EDF in EDPMS	Inward remittance linked by the AD bank	FEMA 23(R)/2026-RB regulations 3 and 5
Claiming a Foreign Trade Policy benefit	eBRC	FTP 2023 para 2.05 and Appendix 2U
Filing FC-GPR for share capital	FIRC and KYC of the investor	RBI FIRMS user manual
Claiming foreign tax credit for tax withheld abroad	Bank advice showing the net amount, plus the foreign tax certificate	Income Tax Act, 2025 section 159; Form 44

Not every service exporter needs an Import Export Code (IEC). Para 2.05 of the Foreign Trade Policy 2023 makes the IEC necessary for services when you want FTP benefits. The DGFT portal, though, will not let you generate an eBRC without a linked IEC. So if you want eBRCs, get an IEC. If you rely only on bank FIRCs for GST, you can work without one.

How do you get a FIRC from your bank?

Ask the branch or relationship manager that holds the account where the money landed. Most banks also let you download a FIRA or FIRC from corporate net banking. Give the transaction reference, the date and the amount. The bank needs the purpose of the remittance on its records before it can issue the certificate.

Here is the sequence we follow for a new client:

1. Tell the foreign customer the exact beneficiary name, account number, SWIFT code and purpose of payment before the first invoice goes out.
2. When the credit arrives, the bank may ask you to confirm the purpose code and give the invoice. Reply the same day so the credit is not parked.
3. Download the FIRA, or request a FIRC through net banking or a letter to the branch.
4. Check the certificate against the invoice before you file it.
5. Save it with the invoice and the GST return for the period of receipt.

The purpose code matters most. A services code tells the bank this is an export receipt. A capital code tells it this is investment, such as share money. If the code is wrong, the IRM may not reach DGFT, and your eBRC cannot be generated. Our guide on purpose codes for foreign remittances lists the common ones.

Field on the FIRC or FIRA	Why a reviewer checks it	What to fix if wrong
Beneficiary name and account	Must match your GST and IEC name	Ask the bank to correct its records
Remitter name and country	Must match the invoice recipient outside India	Get a letter from the customer if a group company paid
Foreign currency amount	Ties to the invoice value	Note short receipts from bank charges
INR amount and rate	Feeds the refund turnover	Use the credited amount, not the invoice rate
Date of credit	Decides the GST relevant period	No fix; plan the claim period around it
Purpose code	Shows a services export	Ask the bank to change it before the eBRC step
Bank reference or IRM number	Links the receipt to DGFT	Ask the bank to push the IRM

Banks charge for FIRCs according to their own schedule. From 1 Oct 2026, regulation 19(3) of the new FEMA export regulations requires AD banks to keep charges reasonable and proportional to the services rendered. A bank also cannot levy a charge or penalty on you for a regulatory delay or violation. Regulation 19(4) makes each bank disclose its policy and the main features of its SOP on its website. If your bank charges per certificate, ask for a monthly consolidated FIRC.

How is an eBRC generated on the DGFT portal?

You generate it yourself. Log in to dgft.gov.in with the IEC linked, go to Services, then eBRC, then Generating eBRC. Pick the IRM your bank pushed and map it to the invoice. Then choose the mode of export of services and submit. DGFT FAQ 29 is clear that you cannot generate an eBRC without an IRM.

The steps on the portal are:

1. Register on the DGFT portal and link your IEC (FAQ 10).
2. Open the list of IRMs the banks have reported against your IEC.
3. Select one IRM, or several IRMs of the same currency from the same bank account (DGFT generation guidelines, 10 Nov 2023).
4. Enter the invoice number, date and value. For services, the portal shows invoices with matching SAC codes.
5. Add foreign bank charges in the invoice details tab where the receipt is short (FAQ 20).
6. Select the mode of export of services under FAQs 88 and 89. Mode 1 is cross border supply and Mode 2 is consumption abroad. Mode 3 is commercial presence and Mode 4 is presence of natural persons.
7. Submit and download the eBRC.

A few rules trip people up:

1. Part payments need a separate eBRC for each payment (FAQ 35).
2. You cannot club two purpose codes in one eBRC, except advance code P0103 with certain codes (generation guidelines).
3. For software and IT services, the guidelines allow only P0802, P0803, P0807 and P0103.
4. The IRM cannot be edited by you. A wrong purpose code needs a request to the bank (FAQ 25).
5. After 120 days you cannot cancel an eBRC yourself. The bank flags it on your request (FAQ 81).
6. Receipts through a payment platform can still give an IRM. Ask your bank to report it, then self certify (FAQ 82).

For volume, DGFT added bulk upload and an API on 20 Aug 2024 through Trade Notice No. 12/2024-25 of 14 Aug 2024. An ERP can push the IRM to invoice mapping straight to DGFT.

How long do you have to realise export proceeds under FEMA in 2026?

From 1 Oct 2026, you must realise export proceeds for services within nine months from the invoice date. Where the invoice is raised or settled in Indian rupees, the period is twelve months. Regulation 5 of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (FEMA 23(R)/2026-RB) sets both limits. Your AD bank can extend them.

The new regulations also bring every service export into a declaration. Regulation 3 asks a services exporter to file an Export Declaration Form (EDF) with the AD bank. The deadline is 30 days from the end of the invoice month. One EDF can cover all exports to one or more recipients in that month.

Under the 2015 regulations, services other than software needed no declaration. Software needed SOFTEX, which ended on 30 Sep 2026. See our notes on the EDF form and on SOFTEX being discontinued.

So the FIRC or IRM now has a second job. Your bank uses it to match the receipt to the EDF in EDPMS. An EDF that stays open past the due date shows as outstanding against your name.

Step	Rule	Time limit	Invoice dated 15 Oct 2026
Raise the invoice	GST invoice rules	When the service is supplied	15 Oct 2026
File the EDF with the AD bank	FEMA 23(R)/2026-RB reg. 3	30 days from the end of the invoice month	30 Nov 2026
Customer remits; bank sends IRM	DGFT eBRC system	When the money lands	Say 10 Dec 2026
Generate the eBRC	DGFT portal	No fixed limit; we do it in the same month	Dec 2026
Realise the full value (foreign currency invoice)	FEMA 23(R)/2026-RB reg. 5	Nine months from the invoice date	15 Jul 2027
Realise the full value (INR invoice or settlement)	FEMA 23(R)/2026-RB reg. 5	Twelve months from the invoice date	15 Oct 2027
Pay IGST if still unpaid (export under LUT)	CGST Rules rule 96A(1)(b)	15 days after one year, or the FEMA period if later	30 Oct 2027
Claim GST refund for the period	CGST Act section 54(1)	Before the expiry of two years from the date of receipt	Before 10 Dec 2028

Regulation 6 helps with small gaps. If the AD bank accepts your reasons, it can allow a reduction in the export value. Where the export value is up to INR 10 lakh per invoice, the bank may allow the reduction on your declaration alone. Regulation 7 lets the bank allow set off against import payables to the same overseas party or its group companies. Regulation 8 lets it permit third party receipts if it is satisfied the deal is genuine.

What changed in 2025 and 2026

The biggest change is the new FEMA export framework from 1 Oct 2026. It moved every services export into an EDF and cut the realisation period back to nine months. Short RBI directions and bank SOPs replaced the old Master Direction. DGFT also changed the eBRC format twice. The table lists each change with its instrument.

Date	What changed	Old position	New position	Instrument
10 Jul 2024	GST payment window for unpaid exports under LUT	15 days after one year from the invoice date, or further time the Commissioner allowed	15 days after one year or the FEMA period with RBI extensions, whichever is later, from the invoice date; the Commissioner can still allow more time	Notification 12/2024-Central Tax
20 Aug 2024	Bulk eBRC and API	One eBRC at a time on screen	Spreadsheet upload and ERP API	DGFT Trade Notice 12/2024-25, 14 Aug 2024
1 May 2025	Mode of export field in services eBRC	No mode captured	Mode 1 to 4 must be chosen	DGFT Trade Notice 02/2025-26, 21 Apr 2025
13 Nov 2025	Realisation period (2015 regulations)	Nine months	Fifteen months	FEMA 23(R)/(7)/2025-RB
13 Jan 2026	eBRC format	One combined "Address/GSTIN" field	An Address field, plus separate GSTIN, GST invoice number and GST invoice date fields	DGFT Public Notice 42/2025-26, 9 Jan 2026 (amends Appendix 2U)
13 Jan 2026	New export regulations notified	FEMA 23(R)/2015-RB	FEMA 23(R)/2026-RB, effective 1 Oct 2026	RBI notification
16 Jan 2026	Bank directions	Master Directions on export and import, 167 circulars	Short directions; old Master Directions superseded from 1 Oct 2026	A.P. (DIR Series) Circular No. 20
5 Jun 2026	Realisation period (2015 regulations)	Fifteen months	Nine months	FEMA 23(R)/(8)/2026-RB
Aug 2026	IRMs from NBFC factors (proposal)	Factor receipts can create duplicate IRMs	Draft SOP only: factors tag the SWIFT message, and exporters see factor IRMs on DGFT	DGFT draft Trade Notice, August 2026 (the draft carries no number)
22 Sep 2026	Realisation period (2026 regulations, before start)	Fifteen months; eighteen for INR	Nine months; twelve for INR	FEMA 23(R)/(1)/2026-RB (Gazette 24 Sep 2026)
1 Oct 2026	Declaration for services	None for most services; SOFTEX for software	EDF within 30 days from end of the invoice month	FEMA 23(R)/2026-RB reg. 3

The August 2026 entry is a draft SOP, not a rule in force. The copy we read carries no notice number or day. Check the Trade Notices page on dgft.gov.in for the final version before you rely on it.

Two points follow for a services exporter in October 2026. First, the fifteen month period under the 2026 regulations never applied, because the 22 Sep 2026 amendment cut it before 1 Oct 2026. Second, if you set up an export invoicing routine before October without EDFs, update it now. Our FEMA compliance service sets up the EDF and eBRC routine together.

How do FIRC and eBRC support a GST refund?

Rule 89(2)(c) of the CGST Rules, 2017 asks a services exporter for a statement of invoices. Each line shows the invoice number and date and the relevant BRC or FIRC. Without that link for each invoice, the officer can reject that part of the claim. The certificate also fixes the amount and timing of your refund.

Under rule 89(4), the refund of unused input tax credit for exports under LUT follows a formula:

Refund = (turnover of zero rated supply of services) × net ITC ÷ adjusted total turnover

Clause (D) of rule 89(4) defines zero rated turnover of services by payments, not invoices. It is the payments received in the period for zero rated services. It adds services completed in the period where payment came in advance earlier. It removes advances for services not yet completed. So the FIRC or eBRC date decides which quarter or month the export counts in.

The relevant date for the two year limit follows the same logic. Explanation 2(c) to section 54 of the CGST Act sets it as the date of receipt. This applies where the service was completed before payment. Where payment came in advance, it is the invoice date.

Refund type	RFD-01 statement	Documents per CBIC Circular 125/44/2019-GST	Our note
Unused ITC on export of services under LUT	Statement 3	Invoices and the BRC or FIRC for each	The FIRC date picks the period
IGST paid on export of services	Statement 2	Invoices, BRC, FIRC or any other document showing receipt	Check whether IGST payment suits your case
Provisional refund	Same statements	Rule 91: 90 percent of the claim for zero rated supplies	Clean FIRC data speeds this up

Circular 125/44/2019-GST lists "BRC/FIRC/any other document indicating the receipt of sale proceeds of services" in its document list. That wording helps when a bank issued only a FIRA. We still prefer an eBRC, because it ties the payment to the invoice number on its face.

Two more GST rules matter here. To export without paying IGST, you file a Letter of Undertaking in Form RFD-11 under rule 96A each financial year. Our guide on LUT filing for exporters covers it.

Rule 96A(1)(b) sets the payment deadline at 15 days after one year from the invoice. If the FEMA period ends later, that period applies. Miss it, and you pay the IGST with interest at the section 50(1) rate. The Commissioner can allow more time.

Does the FIRC matter for income tax?

Income tax does not require a FIRC to report export income. Your books and bank statements are enough for the return. The FIRC helps in two places. It supports a foreign tax credit claim when the customer withheld tax abroad. It also supports transfer pricing files when the customer is your parent company.

When a customer withholds tax abroad, the FIRC shows the net amount received. Gross up to the invoice value in your books and claim credit for the foreign tax. Under the Income Tax Act, 2025, treaty relief sits in section 159. The foreign tax credit statement is Form 44, which replaced Form 67 from tax year 2026-27. Our guide on foreign tax credit and Form 67 covers the claim.

Forms 145 and 146 (old Forms 15CA and 15CB) apply to payments you make to non residents, not to money you receive. See our Form 15CA and 15CB guide for the outward side.

Item	Income Tax Act, 1961	Income Tax Act, 2025 or Rules, 2026	Relevance to service exporters
Treaty relief and foreign tax credit	Section 90	Section 159	Credit for tax withheld abroad
Foreign tax credit statement	Form 67	Form 44	Filed with the return to claim the credit
Payments to non residents	Section 195	Section 393(2), serial 17	Outward only; not for receipts
Remittance information and CA certificate	Forms 15CA and 15CB	Forms 145 and 146	Outward only
Transfer pricing report	Form 3CEB	Form 48 (section 172)	Needed when the customer is an associated enterprise
Tax year	Previous year and assessment year	Tax year (section 3)	Applies from tax year 2026-27

For FY 2025-26, returns and Form 67 still follow the 1961 Act forms. The new form numbers apply from tax year 2026-27.

Which purpose code should the foreign customer use?

The remitter's bank sends a message, and your AD bank assigns a purpose code to the credit. Each type of service has its own code in RBI's list of inward purpose codes. For IT and software services, DGFT's generation guidelines accept only P0802, P0803 and P0807. Advances against exports use P0103.

Give the customer the purpose wording in your invoice and banking details. For example, write "payment for software development services, invoice 2026/45". Your bank reads this when it assigns the code. A foreign owned subsidiary billing its parent should use the services code, not a capital code. A capital code sends the IRM nowhere and makes the bank treat the money as investment.

What if the bank did not issue a FIRC?

Ask for it. A FIRC is issued on request, so a missing one usually means nobody asked. Request it in writing with the date, amount and bank reference. For old receipts, banks can issue a FIRC from their records or give a signed statement of foreign inward remittances. For GST, Circular 125/44/2019-GST also accepts any other document showing receipt.

If the problem is the eBRC, the fix depends on the cause:

Problem	Likely cause	Fix
IRM not visible on DGFT	Bank has not pushed it, or the purpose code is not a trade code	Ask the bank to report the IRM and correct the code (FAQ 25)
IRM shows the wrong IEC	Account not mapped to your IEC in the bank's system	Give the bank your IEC letter and ask it to remap
Receipt older than the bank's cut off date	Legacy period	Ask the bank for a legacy eBRC (FAQs 47 and 48)
Short receipt after bank charges	Intermediary bank deducted fees	Add charges in the invoice details tab (FAQ 20)
Payment through a payment platform	Platform credited a pooled account	Ask the AD bank to report the IRM, then self certify (FAQ 82)
eBRC generated against the wrong invoice	Mapping error	Cancel within 120 days yourself, or ask the bank to flag it after that (FAQs 80 and 81)
Customer paid from a group company	Third party receipt	Get AD bank approval under regulation 8 and a letter from the customer

We see one more cause often. The money landed in an account that is not the one on your GST and IEC records. Fix the records first, then request the certificate.

What happens if export proceeds are not realised?

The consequences come from three laws, and they stack. FEMA treats non realisation as a contravention. GST treats the supply as no longer an export under LUT. The Foreign Trade Policy asks you to return any benefits claimed on that export.

Law	Trigger	Consequence	Source
FEMA	Proceeds not realised in nine months (or extended period)	Penalty up to three times the sum involved, or up to INR 2,00,000 where not quantifiable, plus up to INR 5,000 a day if continuing	FEMA section 13(1)
FEMA	Unrealised for over one year from the due date	Further exports only against full advance or an irrevocable letter of credit	FEMA 23(R)/2026-RB reg. 13
GST	No payment within 15 days after one year (or the FEMA period, if later)	Pay IGST with interest under section 50(1)	CGST Rules rule 96A(1)(b)
GST	Payment not in convertible foreign exchange or permitted INR	Supply is not an export of services	IGST Act section 2(6)(iv)
FTP	Proceeds not realised in the RBI time	Return all FTP benefits on that export	FTP 2023 para 2.54

Regulation 13 also keeps exporters already on RBI's caution list as of 30 Sep 2026 under the 2015 regulations until they are removed. If a customer is slow, ask your AD bank for an extension under regulation 5 before the nine months end. If you have already missed it, the contravention can be compounded with RBI.

Worked example

GST refund for one quarter

A Bengaluru Private Limited company exports software services to its US parent under an LUT. It files refunds quarterly. For July to September 2026 the receipts, all shown on eBRCs, are below. We assume the exchange rates for illustration.

Invoice	Invoice date	Invoice value (USD)	Date received	Rate assumed (INR per USD)	INR credited	Counts in Jul to Sep 2026?
2026/18	31 May 2026	40,000	12 Jul 2026	83.50	33,40,000	Yes
2026/24	30 Jun 2026	40,000	14 Aug 2026	84.00	33,60,000	Yes
2026/31	31 Aug 2026	40,000	Not received	Not applicable	Nil	No
Advance	Not invoiced	10,000	20 Sep 2026	84.50	8,45,000	No, service not completed

The company also made domestic taxable supplies of INR 8,00,000 in the quarter. Its net ITC for the quarter is INR 6,00,000.

1. Zero rated turnover of services = INR 33,40,000 + INR 33,60,000 = INR 67,00,000.
2. Adjusted total turnover = INR 67,00,000 + INR 8,00,000 = INR 75,00,000.
3. Refund = INR 67,00,000 × INR 6,00,000 ÷ INR 75,00,000 = INR 5,36,000.

Invoice 2026/31 waits for the quarter in which its payment arrives. The advance counts in the quarter in which the service is completed. Each line in Statement 3 carries the invoice number and the eBRC number. Suppose the officer disallows the July receipt for want of an eBRC or FIRC and leaves the denominator unchanged. The refund then falls by INR 33,40,000 × INR 6,00,000 ÷ INR 75,00,000 = INR 2,67,200.

An invoice raised after 1 Oct 2026

A Gurugram consultancy invoices a Singapore client USD 25,000 on 15 Oct 2026, under an LUT. It records the taxable value at INR 21,00,000, using an assumed rate of 84.00.

1. The EDF for October is due with the AD bank by 30 Nov 2026.
2. The client pays on 10 Dec 2026. An intermediary bank deducts USD 35, so USD 24,965 arrives.
3. The bank pushes the IRM. The company generates the eBRC and records USD 35 as charges against the invoice.
4. The FEMA realisation deadline was 15 Jul 2027. The receipt is well inside it.
5. The GST refund for the December 2026 period must be claimed before 10 Dec 2028.

Now suppose the client never pays. The rule 96A deadline is 30 Oct 2027, which is 15 days after one year from the invoice. The nine month FEMA period ends earlier, so one year applies. At an assumed 18 percent rate, the IGST is INR 21,00,000 × 18 percent = INR 3,78,000. Interest under section 50(1) comes on top.

The company should also ask its AD bank about reduction in value under regulation 6. The invoice exceeds INR 10 lakh, so a declaration alone is not enough. The bank must accept the reasons.

Common mistakes

1. Waiting for the bank to send a FIRC. Banks issue it on request. Fix: download the FIRA or request the FIRC in the month of receipt.
2. Letting the customer write a vague payment purpose. The bank then assigns a non trade code and no IRM reaches DGFT. Fix: put the purpose wording and invoice number on every invoice.
3. Using invoice dates for the refund formula. Rule 89(4)(D) counts payments received. Fix: build Statement 3 from eBRC or FIRC dates.
4. Mapping one IRM to several invoices with different purpose codes. The portal blocks clubbing of codes. Fix: map per code, and per payment for part payments.
5. Skipping the EDF after 1 Oct 2026. Non software services now need one. Fix: file one EDF per month for all invoices of that month within 30 days of month end.
6. Assuming fifteen months to realise. That period never applied under the 2026 regulations. Fix: diarise nine months from each invoice date.
7. Treating a group company payment as routine. A payment from someone other than the customer is a third party receipt. Fix: get AD bank approval under regulation 8 before you count it.
8. Ignoring short receipts. A USD 35 shortfall leaves the EDF partly open. Fix: record bank charges in the eBRC and ask the bank to close the difference.
9. Generating no eBRC because GST accepts a FIRC. FTP benefits and some buyers need the eBRC. Fix: link the IEC and self certify each month.
10. Keeping certificates in email only. Refund officers and auditors ask years later. Fix: store each FIRC or eBRC with the invoice and the GSTR-1 for that period.

For a foreign owned company, our compliance service for foreign subsidiaries runs this routine every month alongside the GST and FEMA filings.

Checklist

1. Obtain an IEC and link it on the DGFT portal if you want eBRCs or FTP benefits.
2. File the LUT in Form RFD-11 before the first export invoice of the financial year.
3. Give every foreign customer your beneficiary details and the payment purpose wording.
4. Raise each invoice with the client's overseas address, the SAC code and the foreign currency value.
5. File one EDF with your AD bank within 30 days from the end of each invoice month.
6. Confirm the purpose code with the bank when each credit arrives.
7. Download the FIRA or request the FIRC in the month of receipt.
8. Generate the eBRC on DGFT, choosing the mode of export of services.
9. Record bank charges and short receipts against the invoice.
10. Diarise nine months from each invoice date and ask the bank for an extension before it ends.
11. Build Statement 3 of RFD-01 from receipt dates and eBRC or FIRC numbers.
12. File the refund within two years from the date of receipt.
13. Archive the invoice, EDF, FIRC, eBRC and GST return together.

Frequently Asked Questions

What is the full form of FIRC?+

FIRC stands for Foreign Inward Remittance Certificate. It is a certificate your AD bank issues for a foreign currency credit to your Indian account. It shows the remitter, amount, rupee value, date and purpose code. RBI's export directions fix no format for it, so each bank uses its own. You usually have to request it or download it from net banking.

What is the full form of eBRC?+

eBRC stands for electronic Bank Realisation Certificate. Since DGFT Trade Notice 33/2023-24 of 10 Nov 2023, exporters self certify it on the DGFT portal. They map the bank's Inward Remittance Message to an invoice or shipping bill. Its format sits in Appendix 2U of the Handbook of Procedures, 2023.

Is a FIRC mandatory for export of services?+

No law makes a FIRC mandatory as such. You must prove receipt in convertible foreign exchange for the supply to count as an export under section 2(6) of the IGST Act. For a GST refund, rule 89(2)(c) asks for a BRC or FIRC per invoice. In practice, every service exporter claiming refunds needs one of the two.

Can I use an eBRC instead of a FIRC for a GST refund?+

Yes. Rule 89(2)(c) of the CGST Rules, 2017 names the Bank Realisation Certificate or the Foreign Inward Remittance Certificate. An eBRC is a Bank Realisation Certificate in electronic form. We prefer it, because it shows the invoice number on its face. The officer can match each line in Statement 3 directly.

What is an IRM in the eBRC system?+

An IRM, or Inward Remittance Message, is the record your AD bank sends to DGFT for each trade receipt. It carries a reference number, the amount, currency, purpose code and your IEC. You cannot generate an eBRC without one (DGFT FAQ 29). Capital receipts such as share money do not create IRMs.

Do I need an IEC to export services?+

Para 2.05 of the Foreign Trade Policy 2023 needs an IEC for services only when you want FTP benefits. GST refunds work with a bank FIRC alone. The DGFT portal, though, needs a linked IEC before it lets you generate an eBRC. Most regular service exporters get the IEC for that reason.

How long does a service exporter have to receive payment?+

For invoices from 1 Oct 2026, regulation 5 of FEMA 23(R)/2026-RB gives nine months from the invoice date. It gives twelve months where the invoice is raised or settled in Indian rupees. Your AD bank can extend either period on request, so ask before the deadline passes.

Do I have to file an EDF for services after 1 Oct 2026?+

Yes. Regulation 3 of FEMA 23(R)/2026-RB requires an EDF with your AD bank within 30 days from the end of the invoice month. One EDF can cover all exports in that month. Under the 2015 regulations, only software needed a declaration, through SOFTEX.

Can one eBRC cover several payments?+

Yes, within limits. DGFT's generation guidelines allow clubbing IRMs of the same currency received in the same bank account. Two purpose codes cannot be combined in one eBRC, except advance code P0103 with certain codes. Where one invoice is paid in parts, DGFT FAQ 35 asks for a separate eBRC for each payment.

Can I cancel a wrong eBRC?+

Yes. DGFT FAQ 80 lets the exporter cancel an eBRC within 120 days from the date of generation. After 120 days, FAQ 81 says you must go to your bank, which flags the eBRC on your request. Then generate a fresh eBRC against the correct invoice.

What if my client pays through a payment platform?+

Ask your AD bank to report the IRM for that receipt. DGFT FAQ 82 confirms you can then self generate the eBRC. Many platforms issue a FIRA too. Check that it names your company, the remitter and a services purpose code before you rely on it.

Does a short receipt after bank charges cause a problem?+

It can leave the EDF partly open. Record the charges in the invoice details tab when you generate the eBRC, as DGFT FAQ 20 allows. Where the invoice is up to INR 10 lakh, regulation 6 lets the bank allow the reduction on your declaration. Above that, the bank must accept your reasons.

Is a FIRC needed for FC-GPR?+

Yes, for share money received from abroad. RBI's user manual for the FIRMS portal lists the FIRC and the KYC of the foreign investor as attachments to Form FC-GPR. FC-GPR is due within 30 days of allotment under regulation 4(1) of FEMA 395/2019-RB. Ask the bank for the FIRC as soon as the money lands.

Are Forms 145 and 146 needed when I receive money from abroad?+

No. Forms 145 and 146 under the Income Tax Rules, 2026 (old Forms 15CA and 15CB) apply to payments made to non residents. Money you receive for an export of services needs neither form. You need them when your company pays a foreign vendor or parent.

What happens if I never receive payment for an exported service?+

Under rule 96A(1)(b) of the CGST Rules you pay the IGST with interest. The deadline is 15 days after one year from the invoice, or after the FEMA period if later. Under FEMA, ask the AD bank for an extension, reduction in value or write off. Unrealised proceeds can attract a penalty under section 13 of FEMA.

Can a foreign parent pay its Indian subsidiary in rupees?+

Regulation 5 of FEMA 23(R)/2026-RB allows twelve months to realise exports invoiced or settled in Indian rupees. Section 2(6) of the IGST Act accepts INR receipts where RBI permits them. Confirm with your AD bank that the INR route is permitted for that remitter before you invoice in rupees.

Which date counts for the GST refund, invoice or receipt?+

For exports of services, receipt counts. Rule 89(4)(D) measures zero rated turnover by payments received in the period. Explanation 2(c) to section 54 sets the relevant date as the date of receipt, where the service was completed first. For advances, the invoice date is the relevant date.

Where do I check whether an eBRC is genuine?+

The DGFT portal holds the record. The exporter can open the certificate under Services and then eBRC on dgft.gov.in and show it there. DGFT FAQ 48 says banks can view and download exporter generated eBRCs for reconciliation. As a cross check, match the IRM number and amount on the eBRC to the bank's FIRC or FIRA.

Write to [email protected] with a sample FIRC and your last refund claim, and we will tell you what is missing.

Sources

• Reserve Bank of India, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification FEMA 23(R)/2026-RB, 13 Jan 2026, as amended, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13277&Mode=0
• Reserve Bank of India, Directions on Export and Import of Goods and Services, A.P. (DIR Series) Circular No. 20, 16 Jan 2026, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13278&Mode=0
• Reserve Bank of India, Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, 22 Sep 2026, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13714&Mode=0
• Reserve Bank of India, Master Direction on Export of Goods and Services, updated as on 17 Jul 2026 (superseded from 1 Oct 2026), https://www.rbi.org.in/Scripts/BS_ViewMasDirections.aspx?id=10395
• Reserve Bank of India, Foreign Exchange Management (Export of Goods and Services) Regulations, 2015, amended up to 5 Jun 2026, https://rbi.org.in/scripts/NotificationUser.aspx?Mode=0&Id=10256
• Reserve Bank of India, EDPMS: Issuance of Electronic Bank Realisation Certificate, A.P. (DIR Series) Circular No. 04, 15 Sep 2017, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11119&Mode=0
• Reserve Bank of India, User manual for the Single Master Form on FIRMS, https://www.rbi.org.in/scripts/femaview.aspx?femaid=65
• Directorate General of Foreign Trade, FAQs on Self Generation of eBRC, version 1.1, August 2025, https://content.dgft.gov.in/Website/DGFT-FAQs-on-Self-Certification-of-eBRC-dated-1.1.pdf
• Directorate General of Foreign Trade, Self Certified eBRC Generation Guidelines v1.0, 10 Nov 2023, https://content.dgft.gov.in/Website/Self%20Certified%20eBRC%20Generation%20Guidelines%20v1.0.pdf
• Directorate General of Foreign Trade, Self certification of eBRC on the DGFT platform (exporter manual), https://content.dgft.gov.in/Website/Self_Certification_of_eBRC.pdf
• Directorate General of Foreign Trade, Trade Notice No. 12/2024-25, 14 Aug 2024 (refers to Trade Notice No. 33/2023-24 of 10 Nov 2023), https://apeda.gov.in/sites/default/files/dgft_trade_notice/Trade_Notice_12_2024_25.pdf
• Directorate General of Foreign Trade, draft Trade Notice on SOP for reporting of IRMs pertaining to NBFC Factors, August 2026 (copy hosted by APEDA), https://apeda.gov.in/sites/default/files/dgft_trade_notice/Trade_Notice_20_2026_27.pdf
• Directorate General of Foreign Trade, Public Notice No. 42/2025-26, Amendment in Appendix 2U of Handbook of Procedures, 2023, 9 Jan 2026, https://content.dgft.gov.in/Website/dgftprod/76a1eaea-2afd-4468-ad72-b21273b4dcf7/PN%2042%20English_0001%20(1).pdf
• Directorate General of Foreign Trade, Foreign Trade Policy 2023, Chapter 2, https://content.dgft.gov.in/Website/dgftprod/4f665d2f-20cc-4887-ae6a-5ec912bc0d44/FTP2023_Chapter02.pdf
• Directorate General of Foreign Trade, Handbook of Procedures 2023, https://content.dgft.gov.in/Website/dgftprod/e1cb52ea-0c3a-4c2a-8cd7-dd992e9bdc98/HBP_2023.pdf
• Central Board of Indirect Taxes and Customs, CGST Rules, 2017, rule 89, https://taxinformation.cbic.gov.in/content/html/tax_repository/gst/rules/cgst_rules/active/chapter10/rule89_v1.00.html
• Central Board of Indirect Taxes and Customs, CGST Rules, 2017, rule 96A as substituted by Notification 12/2024-Central Tax, 10 Jul 2024, https://taxinformation.cbic.gov.in/content/html/tax_repository/gst/rules/cgst_rules/active/chapter10/rule96a_v1.00.html
• Central Board of Indirect Taxes and Customs, CGST Act, 2017, section 54, https://taxinformation.cbic.gov.in/content/html/tax_repository/gst/acts/2017_CGST_act/active/chapter11/section54_v1.00.html
• Central Board of Indirect Taxes and Customs, Circular No. 125/44/2019-GST, 18 Nov 2019, https://cbic-gst.gov.in/pdf/circular-cgst-125.pdf
• Income Tax Department, FAQs and Guidance Notes on Forms as per Income Tax Rules, 2026, https://www.incometaxindia.gov.in/faqs-and-guidance-notes-on-forms-as-per-income-tax-rules-2026
• Income Tax Department, Section navigator, Income Tax Act, 1961 to 2025, https://www.incometaxindia.gov.in/documents/20117/43138/new-income-tax-bill-2025-navigator.pdf