Oct-1 Readiness Checker — sample report

Risk areas

• Output-IGST pay-and-refund exposure on export invoices

  Without an LUT for the current FY, zero-rated export invoices may need to be issued under an output-IGST pay-and-refund cycle (often at the applicable 18% IT/consulting rate) instead of as zero-rated supply. Delayed-LUT condonation is recoverable in some cases under CBIC Circular 37/11/2018, and refund paths exist for both IGST paid and unutilized ITC. Filing the LUT once at the start of the FY is the cleanest way to avoid the cycle altogether.

  We file this in 24h →

• Open EDPMS entries from prior months

  Each unreconciled inward remittance leaves an open EDPMS entry against your IEC. As entries age past the realization window, AD-bank follow-up + escalation risk increases. Caution-listing itself is decided by RBI on case-specific factors per the current Master Direction — AD-bank recommendation, the exporter's track record, any investigative-agency action, traceability, and whether sincere realization efforts have been made — not as an automatic outcome of an aged entry. The cleanest path is to identify each open entry by IRM number and request closure with the bank.

• Q1-FY27 IGST refund queue forming

  If the LUT isn't on file before Q1 FY27 starts, invoices in that window may need to be issued under an output-IGST pay-and-refund cycle, or covered later via delayed-LUT condonation under CBIC Circular 37/11/2018 — both add cycle time. Filing LUT before May 31, 2026 keeps Q1 clean.

Missing-document checklist

1. Confirm the IEC code on file with your AD bank matches DGFT records

   The new EDF flow requires bank-side IEC linkage to be exact. Mismatches surface only at filing time and block submissions.

2. File LUT for FY 2026-27 on the GST portal (Form GST RFD-11)

   A single filing covers the whole FY and avoids the output-IGST pay-and-refund cycle on subsequent export invoices. Delayed-LUT condonation may still be recoverable under CBIC Circular 37/11/2018, but typically costs cycle time.

   Read more — LUT + IGST refund for Indian service exporters

3. Pull the last 12 months of inward remittance from your bank statement; tag each entry by rail

   This is the input data set for every other action below. Without it, EDPMS reconciliation is guesswork.

4. Ask your AD bank for a list of open EDPMS entries against your IEC, by IRM number

   Every AD bank can pull this. The list is the precondition for clearing each entry one by one.

   Read more — EDPMS closure — the silent FEMA trap

5. Gather FIRA / FIRC / IRM evidence for recent invoices across all rails

   Skydo and Wise typically generate FIRA/FIRC automatically; direct SWIFT usually requires an explicit bank request. The trail supports refund and audit work — and the bank-transmitted IRM is what ultimately unlocks e-BRC self-cert on DGFT.

   Read more — e-BRC for Indian service exporters

6. Self-certify e-BRC on DGFT once a bank-transmitted IRM appears against your IEC

   DGFT's eBRC flow is self-certification against bank-transmitted IRMs (one or multiple). Once an IRM lands at DGFT for an export, you can self-certify the corresponding e-BRC; the FIRC/FIRA evidence supports the broader refund/audit trail rather than gating the self-cert step itself.

   Read more — e-BRC for Indian service exporters

7. Build a one-page map of which clients pay via which rail, with the FX spread per rail

   Multi-rail exporters typically don't realize how much spread differs between rails until they map it. Often surfaces a 1–3% saving by routing differently.

   Read more — 7 FEMA screens Skydo doesn't have

8. Compute IGST-refund-eligible amount for output-tax invoices already paid this FY

   If you've been paying output IGST on exports while sorting LUT, those amounts may be refund-eligible — either as a refund of IGST paid, or as unutilized ITC. Quantify the pool first; choose the path second.

   Read more — LUT + IGST refund for Indian service exporters

Action plan before Oct 1, 2026

• By 31 May 2026

  File LUT for FY 2026-27

  Form GST RFD-11 on the GST portal. Single filing covers the whole FY and avoids the output-IGST pay-and-refund cycle on subsequent export invoices.

• By 30 Jun 2026

  Clear all open EDPMS entries older than 6 months

  Take the IRM-numbered list from your AD bank, match each to its FIRC/FIRA, and file any missing closure documents. The realization-window escalation clock is what to beat.

• By 31 Aug 2026

  Reconcile prior 18 months of inward remittance against EDPMS view

  Bank EDPMS list ↔ your invoice register ↔ rail-by-rail FIRC/FIRA. Goal: zero mismatches between what the bank says is open and what you say is closed.

• By 30 Sept 2026

  Set up monthly EDF filing cadence with your AD bank

  Under the new framework from Oct 1, 2026, every export needs an EDF representation — either per-export or rolled into a monthly EDF ledger entry where services are consolidated. Confirm which path your bank supports and how the handoff works.

• By 01 Oct 2026

  First EDF filing under the new framework

  First export invoice on or after Oct 1, 2026 needs to be representable in the new EDF format. Have the cadence, bank contact, and handoff doc ready before this date — not after.

Bank email templates

Copy-paste templates for the conversations the next 30 days will need. Pre-filled with placeholders — replace the square-bracketed values before sending.

Dear [Bank relationship manager / Trade desk],

I am writing to request a re-issue of FIRC (Foreign Inward Remittance Certificate) for the inward remittance referenced below:

  IRM number: [IRM NUMBER]
  Remittance date: [DATE]
  Currency / amount: [USD AMOUNT]
  Beneficiary IEC: [YOUR IEC]

Please confirm the FIRC is generated against the correct invoice / EDPMS open entry and share a copy at your earliest convenience.

Thank you,
[Your name]

Dear [Bank EDPMS / Trade desk],

Please find below an inward remittance that I believe corresponds to an open EDPMS entry against my IEC:

  IEC: [YOUR IEC]
  IRM number: [IRM NUMBER] (if known)
  Inward remittance date: [DATE]
  Amount: [CURRENCY + AMOUNT]
  Corresponding invoice number: [INVOICE NUMBER]
  Corresponding shipping bill / SOFTEX (if any): [REFERENCE]

Could you confirm whether this remittance has been mapped against the open EDPMS entry, and if not, what additional documentation is required to close it?

Thank you for the help.
[Your name]

Dear [Bank Trade desk],

I'd like to self-certify the e-BRC on the DGFT portal for the export below, but the IRM does not appear to have been transmitted to DGFT yet:

  IEC: [YOUR IEC]
  IRM number: [IRM NUMBER]
  Invoice number: [INVOICE NUMBER]
  Realization date: [DATE]

Could the bank transmit (or re-transmit) this IRM to DGFT so the e-BRC self-certification can proceed?

Thank you,
[Your name]