FEMA & RBI
FEMA Export Proceeds Write-Off
Export proceeds realisation compliance and write-off applications under FEMA — outstanding export bills, BRC reconciliation, AD bank intimation, and RBI application for write-off beyond AD powers. FEMA (Export of Goods & Services) Regulations 2015, realisation period and AD bank write-off limits as currently specified by the RBI, compounding under s.15 FEMA.
Export proceeds realisation compliance and write-off applications under FEMA — outstanding export bills, BRC reconciliation, AD bank intimation, and RBI application for write-off beyond AD powers. FEMA (Export of Goods & Services) Regulations 2015, realisation period and AD bank write-off limits as currently specified by the RBI, compounding under s.15 FEMA. We keep the work founder-friendly and evidence-led so the company can move without unnecessary back-and-forth.
- • Export Write-Off 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
- • Transaction summary and ownership chart
- • Board approvals and valuation support
- • Bank / AD communication
- • Counterparty and remittance details
See the fee table below for the statutory filing charge and common delay logic.
- • Section 7 of FEMA 1999
- • Section 8 of FEMA 1999
- • FEMA (Overseas Investment) Rules 2022
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 write-off 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 Write-Off 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 Write-Off workflow
We start by checking the exact trigger, the legal route, and the documents that make export write-off 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 write-off
- • 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 FEMA & RBI.
- • Cleaner compliance evidence for FEMA & RBI
- • 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 charges can vary with RBI, MCA, DGFT, or exchange filing steps depending on the transaction path.
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
Cross-border structuring, FDI reporting (FC-GPR, FC-TRS), and RBI support with audit-ready documentation and clear timelines
FEMA compliance for Indians investing abroad — ODI under FEMA (Overseas Investment) Rules 2022, LRS advisory, Form ODI filing, overseas valuation certificate, Annual Performance Report
FEMA compounding for regularising foreign exchange contraventions — FDI non-reporting, delayed FC-GPR/FC-TRS, ODI defaults, ECB breaches. Section 15 compounding under the Foreign Exchange (Compounding Proceedings) Rules 2024
DGFT export promotion — EPCG scheme (zero-duty capital goods), Advance Authorisation for duty-free inputs, RoDTEP entitlements, EODC, and IEC registration
FAQ
Frequently asked questions
What does Export Write-Off 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-writeoff
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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.