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From 1 October 2026, Service Exports Need an EDF

Published: 8 October 2026  ·  Facts checked: 8 October 2026

On 1 October 2026, RBI’s new rules on the export and import of goods and services came into force. For businesses in India paid from abroad for services, what matters is a form: the Export Declaration Form (EDF). An exporter of services now declares the full export value on it to their bank, within 30 days from the end of the month in which the invoice was raised. For invoices raised in October 2026, that means by 30 November 2026.

Freelancers and creators asked whether this meant them, and RBI answered on 7 October. Here is what changed, who it reaches, and what to do first.

Update, 8 October 2026: individuals. At RBI’s post-policy press conference on 7 October, Governor Sanjay Malhotra said individuals providing services abroad, such as tutoring or small software work, and getting paid for it, are not required to report, and Deputy Governor Rohit Jain said individuals are not included in the reporting requirements for contracts of a personal nature. RBI will issue FAQs, and the Regulations’ text has not changed. If you earn as an individual, wait for the FAQs or ask your bank before filing. The rest of this post applies in full to firms and companies that export services.

What changed

New regulations. The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB of 13 January 2026, published in the Gazette on 15 January) took effect on 1 October, superseding the 2015 Regulations. RBI’s Directions, A.P. (DIR Series) Circular No. 20, replaced the Master Directions on export and on import of goods and services the same day. RBI calls the new rules “primarily principle based”, aimed at ease of doing business, especially for small exporters and importers.

Services are declared on the EDF. Regulation 3(2) gives an exporter of services “30 days from the end of month in which invoice for services has been raised” to declare the full export value, to the bank where the money arrives (for software, the bank or STPI). Three provisos ease it: one EDF can cover a month’s exports to any number of recipients; an exporter of services other than software may file “on or before the date of receipt of payment”; and the bank can extend the deadline on a request that gives reasons.

One form, software included. The 2015 regime had a separate SOFTEX form for software exports. The 2026 Regulations define one declaration form, the EDF, and name the bank or STPI as the specified authority for software, so software exports are declared on the EDF too.

Nine months to bring the money in, not fifteen. Under regulation 5(1)(a), the full value of a service export must be realised and repatriated within nine months from the date of invoice, or twelve where it is invoiced or settled in rupees. The Regulations as notified in January said fifteen months; an amendment of 22 September 2026 (FEMA 23(R)/(1)/2026-RB, in the Gazette on 24 September) made it nine before the rules took effect.

Small invoices close on your declaration. The bank enters each EDF in EDPMS, the Export Data Processing and Monitoring System, within five working days. For an invoice of up to ₹10 lakh, it may close that entry on your declaration that payment has been realised, in full or otherwise, and you can make that declaration quarterly, in bulk (regulation 4(2)).

RBI was asked to exempt services, and said no

RBI’s statement on the feedback it received records a request that service exports be exempted from the EDF. It was refused: section 7 of FEMA, 1999, RBI said, “makes declaration of exports mandatory”. The process and the timeframe were made flexible instead, and two requests RBI did accept are the ones service exporters will notice: one EDF for a month’s invoices, and closing small entries on a declaration.

RBI also left the procedure to banks. Asked to keep the Memorandum of Instructions on Project and Service Exports, it declined, saying banks can handle these transactions under their own internal policy. The form and the deadlines are RBI’s; the channel (branch, net banking or email), the covering letter and the documents are your bank’s.

Who it reaches

Payments from foreign clients, from freelance platforms such as Upwork and Fiverr, and from YouTube and AdSense are typically received as payment for services supplied abroad, which is why freelancers, consultants, agencies, SaaS sellers and creators all asked about the EDF. Firms and companies that export services, such as agencies, consultancies and SaaS businesses, are squarely covered. For individuals, RBI’s answer of 7 October (above) is that those providing services abroad, such as tutoring or small software work, are not required to report; the FAQs will draw the line.

A business paid by YouTube, AdSense or another platform has one more thing to settle. The 30 days count from the month in which the invoice was raised, but these platforms pay on their own statements, not against an invoice from you. What your bank accepts as the invoice reference is its decision under its internal policy, and so is whether it reads your receipts as services or as software, which the Regulations define to include “audio/video signals”. Ask before you file the first one.

What to do before 30 November

  1. If you earn as an individual, ask your bank first, or wait for RBI’s FAQs (see the update above).
  2. List every invoice you raised to clients abroad in October 2026: client, country, number, date, currency and amount.
  3. Ask your bank how it takes the EDF and what it wants with it.
  4. Fill in one EDF for the month: Part 1 about you and the bank, Part 2B with a row per invoice, and the declaration in Part 4, signed. The EDF form page builds it from your list as a PDF or Word file, and there is a blank EDF to fill by hand.
  5. File it by 30 November 2026. November’s invoices are due by 30 December, and December’s by 30 January 2027.
  6. Note the date nine months after each invoice. The money has to be in by then.

The form, box by box, is in How to File an EDF for Export of Services.

One thing the EDF is not: a tax form. It is a foreign-exchange declaration under FEMA, separate from income tax and GST, which have their own rules. Take those to your CA.

Sources

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