EDF for service exporters: what RBI's new Export Declaration Form actually requires

Until 30 September 2026, an Indian company billing foreign clients for services mostly had nothing to declare to the RBI. Goods exporters filed an EDF, software exporters filed SOFTEX, and a design agency, a consulting firm or a freelancer invoicing in dollars simply received money and got a FIRC.

That ended on 1 October 2026. Under the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, every exporter of services must now file an Export Declaration Form (EDF) stating the full export value of what they invoiced.

Most of what is written about this is secondhand. We read the notification itself, its September amendment, and the RBI circular that accompanies them. Everything below cites the clause it comes from.

The three documents that matter

Document	Date	What it does
Notification No. FEMA 23(R)/2026-RB	13 January 2026 (Gazette: 15 January 2026)	The new Regulations. Replaces the 2015 export regulations, introduces the EDF for services, in force from 1 October 2026
Notification No. FEMA 23(R)/(1)/2026-RB	22 September 2026 (Gazette: 24 September 2026)	Amendment. Cuts the realisation period from 15 months to 9, adds a Caution List carve-out and a transition clause. Also in force from 1 October 2026
A.P. (DIR Series) Circular No. 20	16 January 2026	Instructions to banks. Supersedes the Master Directions on export and import of goods and services and 167 older circulars, including every SOFTEX circular, from 1 October 2026

All three are on the RBI website under Notifications. RBI publishes a consolidated copy of the Regulations “amended up to September 22, 2026”, which is the version to read.

Who files, and with whom

The EDF goes to a “specified authority” (Regulation 2(1)(f)), which depends on what you export and where you sit:

You export	In the Domestic Tariff Area	In an SEZ
Goods	Commissioner of Customs	Development Commissioner
Services other than software	Your Authorised Dealer bank	Development Commissioner
Software	Your Authorised Dealer bank or STPI	Development Commissioner

“Software” is defined broadly (Regulation 2(1)(e)): any computer programme, database, drawing, design, audio/video signal or information on a non-physical medium. The Regulations also say outright that “services” includes software, so software is one kind of service export, not a separate regime.

If you file with STPI or an SEZ, that authority forwards the authenticated EDF to your bank (Regulation 3(3)). Either way, the bank ends up with it, and it enters the details in its Export Data Processing and Monitoring System (EDPMS) within five working days (Regulation 18(1)(b)).

There is no minimum. The Regulations set no turnover or invoice-size threshold for filing. A freelancer with one foreign client files the same form as an IT services company.

The deadline

Regulation 3(2) says an exporter of services must file an EDF within 30 days from the end of the month in which the invoice was raised. Three provisos soften it:

1. One EDF per month is enough. If you invoiced five foreign clients in October, one EDF covers all of them (Regulation 3(2)(a)).
2. Non-software service exporters can file earlier, on or before the date the payment arrives (Regulation 3(2)(b)). Software exporters do not get this option.
3. Your bank can extend the deadline if you ask and give reasons it finds reasonable (Regulation 3(2)(c)).

In practice:

Invoices raised in	EDF due by
October 2026	30 November 2026
November 2026	30 December 2026
December 2026	30 January 2027

The wording of proviso (b) is loose. It does not say whether filing at the time of payment replaces the 30-day deadline when the client pays late, or only lets you file early. Until your bank says otherwise, treat 30 days after month-end as the outer limit and the payment-date option as a way to file sooner.

What goes on the form

The form is the Annex to the Regulations, and it is shared between goods and services. As a services exporter you fill:

• Part 1, General Information: type of export (service), mode of delivery (internet, etc.), category of exporter, AD code, IE Code, GSTIN, PAN, your name and address, mode of realisation, third-party payer details if a third party is paying, country of final destination, description of services, and total value in words (INR).
• Part 2B, Details of Export Value of Services: one row per invoice, with recipient name and address, country, invoice number and date, currency and amount, net realisable value, contract number and date (if any), description of services, and SAC code.
• Part 4, Declaration: you declare that you are the provider of the services and that the declared value is what was contracted, and you undertake to bring the money in by a stated date, within the realisation period.

Shipping bill, port and Let Export Order fields are for goods. Leave them blank.

The form lists IE Code and GSTIN without marking them optional for services. Some explainers say they are not required for services. The Regulations do not say that. Ask your bank what it will accept rather than assuming.

How long you have to collect the money

This is the number most articles got wrong, because it changed after the original notification and before it came into force.

Regulation 5(1), as amended on 22 September 2026:

• Services: 9 months from the invoice date.
• Invoiced or settled in Indian Rupees: 12 months from the invoice date.
• Your bank may extend either period if you ask and it is satisfied with your reasons.

The January notification said 15 months (18 for rupee invoicing). The September amendment replaced both before 1 October, so the longer periods never applied to anyone. If a guide quotes 15 months, it was written before 22 September.

An invoice dated 20 October 2026 must therefore be realised by 20 July 2027.

When the client pays less, pays late, or never pays

The Regulations give banks, not the RBI, the power to deal with the usual problems:

• Reduction in value (Regulation 6). If the client pays less than invoiced, or nothing, your bank can allow a reduction if it accepts your reasons. For invoices up to ₹10 lakh, your own declaration is enough.
• Set-off (Regulation 7). Export receivables can be set off against import payables with the same overseas party, or its group or associate companies, within the realisation period.
• Third-party payments (Regulation 8). A third party may pay you if the bank is satisfied the transaction is genuine. The EDF has fields for the third party and its relationship to you.
• Advances (Regulation 10(1)). If a client pays in advance, route the advance and later receipts through the same bank, or tell both banks if you switch.

There is also a consequence for not collecting. If export proceeds stay unrealised for more than one year past the due date (or any extended date), you can only export further against full advance payment or an irrevocable letter of credit (Regulation 13). For a services business, being forced onto full advance billing is a serious commercial problem, so do not let old invoices sit unresolved.

Exporters already on the RBI’s Caution List on 30 September 2026 stay governed by their existing order until removed (proviso to Regulation 13, inserted in September).

The ₹10 lakh simplification

For invoices up to ₹10 lakh (or the foreign currency equivalent), the bank may close the EDPMS entry on your declaration that the payment has been realised, in full or otherwise, and you may submit these declarations quarterly in bulk (first proviso to Regulation 4(2)). Together with the ₹10 lakh self-declaration route for reductions, this is the main relief for small exporters. It applies to services as well as goods. One explainer describes it as a goods-only relief, which is wrong.

What happened to SOFTEX

Neither Regulation uses the words “SOFTEX abolished”. What actually happened:

• Software is now one kind of service, and its specified authority is “an Authorised Dealer or STPI” (Regulation 2(1)(f)(iii)). It is declared on the EDF like any other service.
• Circular No. 20 supersedes, from 1 October 2026, every circular that set up and amended the SOFTEX procedure, including the 2012 and 2013 “Simplification and Revision of Softex Procedure” circulars and the 2015 bulk SOFTEX circular.

The practical effect is the same: from 1 October 2026 software is declared on the monthly EDF, and STPI certification is optional because your bank can be the specified authority instead. For things done before 1 October, the Regulations keep the old regime in place (“except in respect of things done or omitted to be done before such supersession”). Pending pre-October matters that used to need RBI approval are now handled by your bank (Regulation 20).

What your bank now owes you

The Regulations put real obligations on banks, which exporters should know about:

• Enter your EDF in EDPMS within five working days of receipt (Regulation 18(1)(b)).
• Credit export receipts only after satisfying itself the transaction is genuine, and close or update the EDPMS entry at the same time (Regulation 4(2)).
• Publish an internal policy and SOP for export transactions on its website, covering documents, timelines, charges, extensions, reductions and advances, with a grievance escalation and appeal process (Regulation 19).
• Not levy any charge or penalty on you for a regulatory delay or violation by you, and keep its charges “reasonable and proportional” (Regulation 19(3)).

Banks are still publishing these SOPs, so the filing channel (net banking upload, email, branch) differs from bank to bank. Ask yours before your first deadline.

Penalties

The notification does not set penalties itself. A missed or wrong EDF is a contravention of FEMA, and Section 13 of FEMA applies: a penalty of up to three times the sum involved where it can be quantified, or up to ₹2 lakh where it cannot, plus up to ₹5,000 per day while the contravention continues. Contraventions can be compounded under Section 15.

In practice, the more immediate cost is an open EDPMS entry. It keeps showing up in your bank’s follow-up, and it gets in the way of an eBRC and of GST refunds on zero-rated exports.

Where the explainers go wrong

We read the widely shared guides against the notification. The recurring errors:

• “15 months to realise.” Superseded by the 22 September amendment before it ever applied. It is 9 months (12 for INR).
• “The ₹10 lakh declaration route is for goods exporters.” Regulation 4(2) covers invoices for services too.
• “File with the bank where the payment is finally settled.” The Regulations say the specified authority is an Authorised Dealer. The advance-routing rule in Regulation 10 is the only rule about which bank. Pick one bank per client relationship and be consistent.
• “IEC and GSTIN are not required for services.” The form lists both without an exemption. Your bank may relax this. The Regulations do not.
• “Exporters must send documents to the bank within 21 days.” That was a goods-era rule. Nothing in the 2026 Regulations sets it for services.

A checklist for October onwards

1. Ask your bank how it wants service EDFs submitted, and read its published export SOP.
2. Make sure every foreign invoice has a SAC code, the client’s country, currency and contract reference. These are columns on the form.
3. Each month, list every export invoice dated in that month and file one EDF by the 30th day after month-end.
4. Track every export invoice against its 9-month realisation date. Do it per invoice, because that is how EDPMS tracks it.
5. For short or no payment, file the reduction request (or the ₹10 lakh declaration) before the realisation date, not after.
6. Watch the one-year-past-due line. Crossing it puts you on advance-only exports.
7. Keep FIRCs and bank advices against each invoice, since that is how EDPMS entries get closed.

Most of this list is bookkeeping, not legal work. If your books already record export invoices with their dates, currencies and receipts, the EDF is a monthly report generated from them, and the realisation tracking is a receivables ageing report with a 9-month line drawn on it.

Sources

• Reserve Bank of India, Notification No. FEMA 23(R)/2026-RB dated 13 January 2026, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (amended up to 22 September 2026), including the Annex (Export Declaration Form).
• Reserve Bank of India, Notification No. FEMA 23(R)/(1)/2026-RB dated 22 September 2026, Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026.
• Reserve Bank of India, A.P. (DIR Series) Circular No. 20 dated 16 January 2026, Export and Import of Goods and Services.

This note explains the Regulations. It is not legal advice for your specific case.