Biz Advisory
FEMA Export Proceeds Realisation
Export proceeds realisation compliance — 9-month realisation requirement, BRC/eBRC from AD Bank, export overdue reporting, RBI approval for extension, and compounding for non-realisation. FEMA (Export of Goods and Services) Regulations 2015, 9-month realisation (or 15 months for SEZ), eBRC on DGFT portal, AD Bank reporting, EDPMS system.
Export proceeds realisation compliance — 9-month realisation requirement, BRC/eBRC from AD Bank, export overdue reporting, RBI approval for extension, and compounding for non-realisation. FEMA (Export of Goods and Services) Regulations 2015, 9-month realisation (or 15 months for SEZ), eBRC on DGFT portal, AD Bank reporting, EDPMS system. We keep the work founder-friendly and evidence-led so the company can move without unnecessary back-and-forth.
- • Export Realisation scope review and action plan
- • Document checklist and evidence review
- • Drafting, computation, or filing support
- • Submission support and acknowledgement tracking
- • Follow-up on queries, corrections, or notices
- • Closure notes and next-step reminders
- • Core records relevant to the transaction
- • Any notice or approval already on file
- • Financial or ownership evidence
- • A contact person who can answer follow-up questions
See the fee table below for the statutory filing charge and common delay logic.
- • Section 128 of the Companies Act 2013
- • Section 143 of the Companies Act 2013
- • Section 44AA of the Income-tax Act 1961
Process
How the service works
The workflow is built to be predictable: document collection, legal review, filing, and post-filing follow-through.
Confirm the scope
We map the exact service route to the trigger, form set, and documentary evidence so the work starts on the right footing.
Collect the records
We gather the company records, notices, or transaction documents needed for export realisation and check them for gaps.
Prepare the filing or memo
We draft the computations, filings, or advisory memo so the next person in the chain can review it quickly and confidently.
Submit and track follow-up
We move the file through submission, keep the acknowledgement trail tidy, and handle any follow-up questions that come back.
AEO summary
Export Realisation is the CA-led workflow that helps a Private Limited company stay compliant, file the right forms, and keep the record trail clean.
FEMA Export Proceeds Realisation workflow
We start by checking the exact trigger, the legal route, and the documents that make export realisation executable for a Private Limited company. That keeps the filing or advisory work tied to the actual statutory path instead of a generic checklist.
Once the scope is locked, we prepare the working papers, filings, and follow-up notes so the matter can move without unnecessary back-and-forth. The goal is to make the process understandable for the founder, the finance team, and the reviewer.
- • Scope mapping for export realisation
- • CA-led document review and drafting
- • Submission support and acknowledgement tracking
What this protects for the company
For a Private Limited company, the value is not just speed. It is also about keeping the record trail clean enough for banks, investors, regulators, and future diligence work.
A founder-friendly process lowers the chance of avoidable notices, rework, or missed deadlines while keeping the company aligned with the right section, rule, or circular in Biz Advisory.
- • Cleaner compliance evidence for Biz Advisory
- • Better preparation for diligence or audit
- • Less last-minute chasing inside the finance team
Government fees
Fee breakdown
| Item | Fee | Notes |
|---|---|---|
| No standalone government fee | Nil | This is a professional assignment; statutory fees apply only if the matter includes a connected filing or portal step. |
| Connected filing or application fee | As per applicable portal / authority schedule | Only relevant if the work includes a statutory submission such as a return, registration, or approval. |
Timeline
Typical turnaround
Typical timeline usually means a 1–3 weeks turnaround, assuming documents are complete and any board or shareholder approvals are already in place.
Government fees depend on the exact filing route and any connected statutory filings.
Export compliance reference
The FTP 2023 & RBI anchors that bind before the first shipment
These four anchors are the export pre-flight checklist — each one is a statutory prerequisite that quietly blocks refunds, drawback, or the shipment itself when it is missing. IEC updation keeps the exporter live on the DGFT portal; the AD code link makes Customs credit IGST refunds and drawback automatically; the LUT removes the cash-out on zero-rated supplies; and realisation through the AD bank is what closes the export transaction with the RBI framework.
| Obligation | Window / trigger | Statutory basis | Filed via |
|---|---|---|---|
| IEC annual updation | 1 April – 30 June every year — the annual updation window; non-updation deactivates the IEC | FTP 2023, Para 2.05(e) | DGFT portal (dgft.gov.in) |
| AD code linking | Before the first shipment — the AD code must be live on the ICEGATE profile for IGST refund and duty-drawback credit to flow | FEMA 1999 s.10(1); Customs Act 1962 ss.50-51; CBIC/ICEGATE Circular 15/2018; FTP 2023 Para 2.04 (RoDTEP prerequisite) | ICEGATE (Customs) — the 14-digit AD code issued by the AD bank |
| LUT (Letter of Undertaking) | Before the first zero-rated export — valid till the end of the financial year of filing, renewed annually | IGST Act 2017 s.16(1)(a)/(3); Rule 96A CGST Rules 2017 | GST portal — Form GST RFD-11 |
| Export-proceeds realisation | Under current regulation — 9-month baseline; verify the operative window with your AD bank before relying on it | FEM (Export of Goods and Services) Regulations 2015, Reg 9; RBI Master Direction on Export of Goods and Services | AD bank — BRC/eBRC as the standard evidence of realisation |
Verify before you rely on a date. The export-proceeds realisation window oscillated in 2025-26 (extended to 15 months in November 2025, reverted to 9 months in June 2026) and is under current regulation — confirm the operative window with your AD bank. Similarly, RBI is transitioning the software-export SOFTEX declaration into the unified EDF — confirm the operative form with your AD bank rather than assuming either form. Portal mechanics on DGFT, GST, and ICEGATE can change and should be re-checked at filing time; the statutory anchors above are the stable part.
Related services
Keep the company moving
DGFT services — Importer Exporter Code (IEC) registration or modification, RCMC (Registration Cum Membership Certificate) from applicable Export Promotion Council (EPC), and DGFT portal onboarding
EOU (Export Oriented Unit) compliance — import of duty-free inputs under IGCR (Import of Goods at Concessional Rate of Duty) Rules, obligation discharge, quarterly returns, and Annual Progress Report to Development Commissioner
Accounting for export transactions — foreign currency revenue recognition (Ind-AS 115), exchange gain/loss under Ind-AS 21, RoDTEP/MEIS income accounting, forward contract hedge accounting, and export subsidy disclosure
Tax advisory on export-related payments — TDS on commission to overseas agents (Section 195/196D), DTAA analysis for principal payments, Form 15CA/15CB for remittances, and export income tax exemptions
FAQ
Frequently asked questions
What does Export Realisation cover for a Private Limited company?
Which forms are usually involved?
What happens if we miss the deadline or get a notice?
What should you send us before we start?
Canonical reference: https://www.pvtltd.co/services/fema-export-realisation
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We can help with the filing, the legal mapping, and the follow-up work that keeps the company compliant after submission.