EDF (Export Declaration Form) for Service Exporters: The New FEMA Rule from 01.10.2026
Companies, LLPs, firms and other businesses billing overseas clients now have a monthly declaration to file with their bank. Here is who is covered after RBI's 07.10.2026 clarification on individuals, the deadlines, the shorter 9-month realisation window, and what to do this month.
Until 30.09.2026, most Indian service exporters never had to declare their exports to anyone - only goods exporters (EDF) and software exporters (SOFTEX) did. From 01.10.2026, that gap is closed for businesses: a company, LLP or firm exporting services must now furnish an Export Declaration Form to its bank for every month in which it raises an export invoice. After a week of confusion, RBI said on 07.10.2026 that individuals are not covered for transactions of a personal nature - which changes the answer for many freelancers and creators.
What Is EDF?
EDF stands for Export Declaration Form. It is the form in which an exporter tells its bank the full value of what it has exported - client by client, invoice by invoice - and undertakes to bring that money into India within the prescribed time. Until 30.09.2026 the EDF was used only for exports of goods. From 01.10.2026 it also covers services and software, and replaces the old SOFTEX form for software.
The EDF is not filed on any government portal. You give it to your bank (the Authorised Dealer, or AD bank), and the bank reports it to RBI through its Export Data Processing and Monitoring System (EDPMS).
What Has Changed
The Reserve Bank of India notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB dated 13.01.2026). They came into force on 01.10.2026 and replace the 2015 export regulations, bringing goods, software and all other services under one declaration form - the Export Declaration Form (EDF).
| Particulars | Up to 30.09.2026 | From 01.10.2026 |
|---|---|---|
| Services other than software (consulting, design, content, marketing, professional services) | No declaration required | EDF mandatory |
| Software exports | SOFTEX form | EDF - SOFTEX discontinued |
| Goods exports | EDF at the time of export | EDF, treated as part of the shipping bill at EDI ports |
| Time limit for services | Not applicable (other than SOFTEX) | 30 days from the end of the month of invoice |
Who Must File
Regulation 3(2) applies to "an exporter of services", with no threshold by turnover or invoice value. Read with RBI's clarification of 07.10.2026, the position now splits into two groups.
Covered - Businesses Exporting Services
- Private and public limited companies, including IT and IT-enabled service companies, BPOs, KPOs and global capability centres (GCCs) billing overseas parent or group entities
- LLPs and partnership firms - consultancies, professional firms of CAs, lawyers and architects, design and engineering studios
- Agencies offering digital marketing, social media management, research or back-office support to foreign businesses
- Any other entity raising invoices on overseas clients - there is no small-value exemption from the EDF itself; the ₹10 lakh relaxation is for closing entries, not for filing
Individuals - Not Covered for Transactions of a Personal Nature
- RBI has said individuals are outside the reporting requirement for contracts of a personal nature - the Governor's examples were tutoring or small software work for someone abroad. RBI did not mention any value limit, and did not define "personal nature"
- This is widely being read as covering individual freelancers, independent professionals and content creators working in their own name
- Grey area until the FAQs: a sole proprietorship run as a regular business - with a trade name, GST registration and LUT, staff, or many overseas clients - may not be treated as "personal". Until RBI's FAQs say otherwise, such proprietors should check with their bank rather than assume they are out
- Being outside the EDF does not remove the duty to realise and repatriate export earnings, or the GST and income tax treatment of that income
When to File - The 30-Day Rule
The EDF must be furnished within 30 days from the end of the month in which the export invoice is raised. The clock runs from the invoice month - not from when the work was completed or when payment arrives. Three relaxations are built in:
Relaxations Under Regulation 3(2)
- One EDF a month: a single consolidated EDF can cover all services exported to one or more overseas clients during that month
- On or before payment (non-software only): an exporter of services other than software may furnish the EDF on or before the date the payment is received - read conservatively, this means whichever of the two dates comes first (see the note below). Software exporters, including design and video businesses caught by the wide definition, stay on the 30-day limit alone
- Extension by the bank: the Authorised Dealer (AD) bank may extend the deadline on a request explaining the reason for delay, if it finds the request reasonable
First Three Due Dates
The first EDF under the new regime. Invoices dated up to 30.09.2026 stay under the old framework.
One consolidated EDF for all overseas invoices raised in November.
And so on every month - within 30 days from the end of the invoice month.
Where to File and What It Contains
| Nature of Export | Unit Outside an SEZ | Unit in an SEZ |
|---|---|---|
| Services other than software | Your AD bank | Development Commissioner of the SEZ |
| Software | Your AD bank or STPI | Development Commissioner of the SEZ |
Where the EDF goes to STPI or the SEZ authority, they forward the authenticated form to your AD bank. The form itself is annexed to the Regulations. For each overseas client it captures the name, address and country, invoice number and date, currency and amount, net realisable value, contract reference, a description of the service and its Service Accounting Code (SAC). The general part has fields for the IE Code, GSTIN, PAN and AD code, and you undertake to bring the full export value into India through the AD bank within the realisation period.
The mode of submission - branch, net-banking portal or email - is set by each bank's own standard operating procedure, which banks are required to publish. Collect your bank's procedure before your first due date, and check which of the identification fields it treats as mandatory in your case. Two fields need preparation in advance: the SAC for every service you bill (most exporters have never tracked it outside their GST invoices), and your PAN, against which the bank opens the EDPMS entry. Note also that the net realisable value is what you expect to receive after deductions, which is not always the gross invoice amount.
What Happens After You File - EDPMS and the 9-Month Clock
Every EDF is entered by the bank in the Export Data Processing and Monitoring System (EDPMS) within five working days. That entry stays open until the export value is realised. When the overseas payment arrives, the bank records an Inward Remittance Message (IRM) and matches it to the open entry. The bank credits an inward remittance only after satisfying itself that the transaction is genuine, and closes or updates the EDPMS entry at the same time - so a missing EDF can mean a remittance is held or queried.
Connected Rules Once an Invoice Is Declared
- Realisation: the full value must be realised and repatriated within 9 months from the invoice date (12 months where invoiced or settled in Indian Rupees); the AD bank can extend this on a reasoned request
- Small invoices: for invoices up to ₹10 lakh, the EDPMS entry can be closed on your own declaration that payment has been realised, and such declarations can be given quarterly in bulk
- Reduction in value: if a client pays less than invoiced (discount, dispute, bank charges), the AD bank can approve the reduction; up to ₹10 lakh per invoice on your declaration
- Set-off and third-party receipts: receivables can be set off against payables to the same overseas party or its group, and payment from a third party is allowed if the bank is satisfied of its bona fides
- Advance receipts: an advance and the later realisation should go through the same AD bank, or another only after informing both
- Long-pending dues: where proceeds remain unrealised for over a year beyond the due date, further exports may be allowed only against full advance payment or an irrevocable letter of credit
- Bank charges: under Regulation 19(3), the AD bank cannot levy any charge or penalty on you for a regulatory delay or violation on your part; its charges for handling transactions must be reasonable. Ordinary service fees - for example for issuing an eBRC or eFIRC - may still apply, and should be listed in the bank's published policy
Examples: How It Works in Practice
Who: Pixelcraft Design Studio LLP, a three-partner UI design firm in Hyderabad, works for a US start-up and a UK agency.
- October 2026: The LLP raises an invoice of USD 3,000 to the US client on 10.10.2026 and GBP 1,200 to the UK client on 24.10.2026.
- Covered? Yes. The LLP is a business entity, so RBI's clarification on individuals does not apply to it.
- Software or other services? The LLP delivers UI designs as digital files. Since "software" includes any design on a non-physical medium, it should treat itself as a software exporter. The option to file on or before receipt of payment is therefore not available - its only limit is 30 days from the end of the invoice month.
- EDF: One consolidated EDF covering both invoices, with the SAC for UI design services against each. The outer limit is 30.11.2026, but the US client is expected to pay in early November - so the LLP files the EDF with its AD bank on 02.11.2026, as soon as October closes, so that the entry is already in EDPMS when the money arrives. The bank, not the LLP, then reports it on RBI's EDPMS platform.
- Payment: The US client pays on 05.11.2026. The bank matches the remittance to the EDPMS entry already in place and credits it without delay. Since the invoice is under ₹10 lakh, the entry can be closed on the LLP's own declaration.
- Realisation deadline: The UK client is slow to pay. The 9-month window from 24.10.2026 runs to 24.07.2027 - after that, the LLP must seek an extension from its bank.
- Quiet months: In any month with no export invoice, there is nothing to declare for that month.
Who: Meera runs a cooking channel from Hyderabad in her own name. She is paid monetisation revenue by the overseas platform entity, and does occasional recipe-writing work for a Singapore kitchenware brand.
- Covered? On RBI's 07.10.2026 clarification, an individual is not covered by the reporting requirement for transactions of a personal nature. Meera, earning in her individual capacity, is very likely outside the EDF - subject to the FAQs RBI has promised.
- What could change that: if she later runs the channel through a company or LLP, that entity will be covered. If she operates as a full-fledged proprietorship business, she should confirm her position with her bank once the FAQs are out.
- What does not change: her overseas earnings must still come into India through banking channels, and they remain taxable in her income tax return. Her GST position on these receipts is a separate question.
- Records to keep anyway: invoices or self-generated documents for platform payouts, platform earnings statements, the brand agreement and bank remittance advices. If the FAQs do bring some individuals in, she will be ready.
Consequences of Not Filing
Failing to furnish the EDF is a contravention of Section 7 of the Foreign Exchange Management Act, 1999 read with Regulation 3. Under Section 13, the penalty may extend to three times the sum involved where it can be quantified, or up to ₹2 lakh where it cannot, plus up to ₹5,000 for every day the contravention continues. Contraventions can be compounded under Section 15 on application.
The practical consequence usually comes first. A remittance with no matching EDF has no EDPMS entry, so the bank may delay the credit, and the entry cannot be closed. That in turn holds up the electronic Bank Realisation Certificate (eBRC), which is generated on the DGFT portal once the bank has matched the payment to the declared invoice. The eBRC matters beyond FEMA - for GST, receiving payment in convertible foreign exchange (or in Indian Rupees where RBI permits) is one of the conditions for a supply to qualify as an export of services, and the eBRC is the evidence most commonly relied on in refund claims.
How This Fits With GST and Income Tax
The EDF does not change how your foreign income is taxed, but it creates a third record of the same invoices. Export turnover declared in your EDFs should reconcile with zero-rated turnover in your GST returns and with export revenue in your books and income tax return. A mismatch between these is exactly the kind of gap that now becomes visible. For how foreign income is taxed and reported in India, see our Foreign Income Tax Compliance guide; freelancers reporting this income as business or professional income should also note the ITR due date that applies to business income.
Action Checklist for This Month
For Businesses - Before Your First EDF Is Due on 30.11.2026
- Identify every bank account in which you receive foreign remittances, and decide which AD bank each client's payments will go to - the EDF should go to the bank through which that invoice will be realised
- If clients pay you through a payment platform or cross-border payment aggregator, find out which AD bank finally settles those funds and how that bank wants the EDF - some platforms require the EDF before the payment can be collected. A FIRA or e-FIRC from the platform proves the money arrived; it does not replace the EDF
- Obtain your bank's EDF procedure (format, portal or branch, documents) and the fields it treats as mandatory
- Decide whether what you export is "software" (programmes, databases, designs, drawings, audio or video files) or other services - it changes your deadline
- Map every service you bill to its SAC, and set up a monthly statement of export invoices, client-wise, with SAC, currency, amount and contract reference - this feeds the EDF directly
- Diarise the 30-day deadline each month, and the 9-month realisation date for every invoice
- Route any advances from overseas clients through the same AD bank that will receive the EDF
- Reconcile EDF totals with your GST returns and books every quarter
Frequently Asked Questions
EDF is the Export Declaration Form under FEMA. It declares the full value of goods, software or services exported, and is furnished to your AD bank (or STPI or the SEZ authority, where applicable) - not on any government portal. The bank then reports it to RBI.
Very likely not. RBI said on 07.10.2026 that individuals are not covered by the reporting requirements for contracts of a personal nature, and that FAQs will follow. "Personal nature" has not yet been defined. If you operate as a regular proprietorship business - with a trade name, GST registration and LUT, or staff - confirm your position with your bank once the FAQs are issued. Your earnings must still be received through banking channels and reported for income tax.
No. There is no threshold for filing the EDF itself. The ₹10 lakh limit relaxes the closure of the EDPMS entry - for invoices up to that value, the entry can be closed on the company's own declaration that payment has been received, and such declarations can be given quarterly.
No. The reporting on RBI's platform (EDPMS) is done by your AD bank, but the bank does that using the EDF you furnish to it. A covered business still gives the EDF to its bank; it does not have to log in to any RBI portal itself.
No. A FIRA or e-FIRC only proves that money came in. The EDF is a separate declaration of the export itself, and the bank needs both to match the payment and close the entry. File the EDF with the AD bank where the platform finally settles your funds - which may not be the bank named on the FIRA - and check whether that bank or platform wants it before the payment is collected.
Very likely yes. The Regulations define software to include any drawing, design or audio or video signal on a non-physical medium. Software exporters must file within 30 days from the end of the invoice month and cannot use the option of filing on or before receipt of payment.
No. One consolidated EDF can cover all services exported to one or more overseas clients in a month.
No. Invoices dated up to 30.09.2026 continue under the earlier framework. The EDF requirement applies to service export invoices raised on or after 01.10.2026, even if the payment for an earlier invoice arrives later.
Nine months from the invoice date, or twelve months where the invoice is raised or settled in Indian Rupees. The 15 and 18 months quoted in some early commentary were reduced by the amendment of 22.09.2026 before the Regulations came into force. Your AD bank can extend the period on a reasoned request.
File the EDF with your bank as soon as possible with a request explaining the reason for the delay - the AD bank has the power to extend the period if it finds the reason reasonable. Do not wait until the remittance arrives and is held up.
No. The EDF is a FEMA reporting requirement. Income tax and GST on export income continue as before - but the figures you declare in the EDF should match what you report for GST and income tax.
For how foreign earnings, foreign assets and Schedule FA reporting work for residents, see our Foreign Income Tax Compliance article. For general questions on filing your return, see ITR Filing Essentials, or contact us to set up your EDF routine.