Invoicing a foreign client in Indian rupees does not take you out of the EDF: you still declare the invoice on the monthly form, with INR in the currency column of Part 2B. What changes is the deadline for getting paid. Under Regulation 5(1)(a), services invoiced or settled in Indian rupees get 12 months from the invoice date for full realisation, instead of the usual 9 months.
Key takeaways
- Rupee invoices to foreign clients still go on your monthly EDF, filed within 30 days from the end of the invoice month.
- The realisation window is 12 months for rupee-invoiced or rupee-settled services, versus 9 months for foreign currency.
- In Part 4, you strike out "foreign exchange" so the declaration reads "Indian Rupees".
- Rupee settlement often runs through a Special Rupee Vostro Account (SRVA) held by the client's bank with an Indian bank.
- GST zero-rating needs payment in convertible foreign exchange or in rupees where RBI permits, so confirm the route with your CA.
Why rupee invoicing is on the rise
For years, almost every Indian services exporter billed in dollars, euros or pounds. Rupee invoicing has become more common as RBI has opened routes for settling cross-border trade in INR, most visibly through the SRVA mechanism, where a foreign bank holds a rupee account with an Indian bank and uses it to pay Indian exporters.
From the exporter's side, a rupee invoice removes currency risk on the invoice itself: you bill ₹6,50,000 and expect ₹6,50,000. The trade-off is that the client carries the currency exposure and may take longer to arrange payment. Helpfully, the regulations give rupee transactions a longer realisation window.
Our detailed explainer on rupee invoicing and SRVA accounts covers the banking mechanics. This article sticks to what changes on your EDF.
How a rupee invoice looks on the EDF
Most of the form is filled exactly as for any other services export. The differences are small but easy to get wrong.
| EDF field | Foreign-currency invoice | Rupee invoice |
|---|---|---|
| Part 2B currency | USD, EUR, GBP, etc. | INR |
| Part 2B amount | Invoice value in that currency | Invoice value in rupees |
| Part 2B NRV | Expected net receipt in that currency | Expected net receipt in rupees |
| 1.22 total value in INR | Converted at your chosen rate | Added directly, no conversion |
| 1.12 mode of realisation | Usually "Others" | Usually "Others" |
| Part 4 alternative | Keep "foreign exchange" | Keep "Indian Rupees" |
| Realisation date in Part 4 | Within 9 months of invoice date | Within 12 months of invoice date |
The Part 4 declaration is where people slip. It contains pairs of alternatives, and one of them is "foreign exchange / Indian Rupees". For a rupee invoice, strike through "foreign exchange". If your month mixes rupee and dollar invoices on one EDF, ask your bank how it wants the declaration presented, because a single strike-out cannot describe both.
The 12-month window, worked through
The clock runs from each invoice date, not from the end of the month or the EDF filing date. Here is how the same three invoice dates play out under both rules.
| Invoice date | Foreign currency (9 months) | Indian rupees (12 months) |
|---|---|---|
| 5 November 2026 | 5 August 2027 | 5 November 2027 |
| 18 December 2026 | 18 September 2027 | 18 December 2027 |
| 22 January 2027 | 22 October 2027 | 22 January 2028 |
Take Kaveri Analytics LLP, a Hyderabad data engineering firm. In December 2026 it bills a client abroad ₹8,40,000 for a dashboard build, with settlement agreed in rupees through the client's bank's vostro account in India. Kaveri files its December EDF by 30 January 2027, showing INR in Part 2B and striking out "foreign exchange" in Part 4.
The client pays ₹4,20,000 in April 2027 and the balance in October 2027. Both payments fall inside the 12-month window ending 18 December 2027, so there is nothing to extend. Had the same invoice been in dollars, the second payment would have fallen outside the 9-month window, and Kaveri would have needed to ask its AD bank for an extension.
You can check any date quickly with the EDF due date calculator, and our guide to the 9-month realisation rule explains extensions in detail.
Questions to settle before you invoice in rupees
Is it invoiced or only settled in rupees?
The regulation speaks of services invoiced or settled in Indian rupees. If your invoice is in dollars but the client wants to pay rupees, or the reverse, ask your AD bank in writing which window it will apply to that invoice. Do not assume the longer period.
Which bank account receives the money?
Rupee settlement through a vostro account still lands with an Indian bank, and the bank that receives the payment is normally the AD bank for your EDF. If that is not the bank where you usually file, sort out the arrangement before the first invoice.
Does it still count as an export for GST?
The GST definition of export of services requires payment in convertible foreign exchange, or in Indian rupees wherever RBI permits. A properly routed rupee settlement may meet that condition, but a client simply transferring rupees from some domestic account may not. Get your CA's view before you rely on zero-rating under your LUT.
Common mistakes with rupee invoices
The most frequent error is treating a rupee invoice as a domestic sale and leaving it off the EDF altogether. The recipient is still abroad and the service is still exported, so the invoice belongs in Part 2B with everything else from that month.
The second is writing the Part 4 realisation date using the 9-month rule out of habit. That understates the time you actually have, which is harmless on its own but becomes confusing when the bank later reviews open entries.
The third is forgetting the invoice when preparing the ₹10 lakh realisation declaration. Rupee invoices up to ₹10 lakh can be closed on your declaration just like foreign-currency ones, so include them in your periodic declaration once paid.
This is general information, not legal or tax advice. Rupee settlement routes are still evolving, so confirm the current position with your AD bank and CA.
Frequently asked questions
Do I need to file an EDF for an invoice raised in Indian rupees?
Yes, if you are a covered exporter and the service is exported to a recipient outside India. The rupee invoice goes into Part 2B of that month's EDF with INR as the currency, and it is due along with your other invoices within 30 days from the end of the month.
How long do I have to get paid on a rupee invoice?
Regulation 5(1)(a) gives 12 months from the invoice date where the export is invoiced or settled in Indian rupees. The AD bank can extend this on a reasoned request, just as it can for the 9-month foreign-currency window.
Can one EDF include both rupee and dollar invoices?
One EDF covers all service exports of a month, so both types can appear as separate rows in Part 2B. Each row shows its own currency. Because the Part 4 declaration offers a single "foreign exchange / Indian Rupees" choice, ask your bank how it wants a mixed month presented.
What is an SRVA and do I need one?
A Special Rupee Vostro Account is a rupee account that a foreign bank keeps with an Indian bank to settle trade in INR. You, as the exporter, do not open it; your client's bank does. You simply receive the rupee payment into your own Indian account through that arrangement.
Bottom line
A rupee invoice is still an export, still goes on the monthly EDF, and simply earns a 12-month realisation window in place of 9. Mark INR clearly in Part 2B, get the Part 4 strike-out right, and build the form in minutes with our free EDF form generator.
This guide is general information for Indian businesses, not legal or tax advice. Rules and bank processes change — confirm specifics with your AD bank or chartered accountant.