If you invoice overseas clients, your compliance calendar just changed. The Reserve Bank of India notified the new export regulations on 13 January 2026, and they took effect on 1 October 2026. For many service businesses, this is the first time they must declare exports in a prescribed form. The first monthly EDF, covering October 2026 invoices, falls due on 30 November 2026.
What is the Export Declaration Form (EDF)?
The EDF is a foreign exchange declaration under the Foreign Exchange Management Act, 1999. The exporter states the full export value of goods, services or software. It is not a tax return and not a customs document. Its job is to let the AD bank open an entry in RBI's export monitoring system (EDPMS) so that the receipt of foreign exchange can be tracked until the export value is realised.
The governing instrument is Notification No. FEMA 23(R)/2026-RB dated 13 January 2026, read with the amendment notified on 22 September 2026 (FEMA 23(R)/(1)/2026-RB). For services, the key provision is Regulation 3(2).
What changed from 1 October 2026?
| Area | Earlier (2015 framework) | Now (2026 Regulations) |
| Goods | EDF / SDF with shipping bill | Single EDF; deemed filed with the shipping bill at EDI ports |
| Software | SOFTEX form, certified through STPI/SEZ | SOFTEX removed; software treated as a service and covered by the EDF |
| Other services | Generally no export declaration | Monthly EDF through the AD bank |
| Role of AD bank | Limited for software | Recognised as a specified authority on par with STPI |
| Bank reporting | - | AD bank updates EDPMS within 5 working days of receiving a service EDF |
Who must file the EDF?
| Type of exporter | EDF required? | Notes |
| Goods exporters | Yes | Declared at the time of export; at EDI ports, the EDF is deemed part of the shipping bill. A traveller moving personal effects out of India is not an exporter. |
| Software / IT / ITeS / SaaS exporters | Yes (replaces SOFTEX) | One consolidated EDF per month for exports made on or after 1 October 2026. |
| Other service exporters: consultants, agencies, professional firms, BPOs, GCCs | Yes | New obligation for most of these businesses. No general small-value exemption appears in Regulation 3(2). |
| Individuals (personal-nature transactions) | No, per RBI clarification of 7 October 2026 | RBI cited examples such as earning from tutoring or small software work from abroad. FAQs are awaited. |
| Freelancers invoicing as a business (firm name, GSTIN, proprietorship) | Treat as in scope until RBI's FAQs settle it | Confirm with your CA and AD bank. |
Watch the definition of "software". The Regulations define it broadly, covering computer programmes, databases, drawings, designs, and audio or video content on a non-physical medium. A design studio, video editor or architect sending files abroad may fall in the software category, which means the stricter 30-day filing clock with no option to file on the payment date.
Where to submit the EDF?
| Export Category | Specified Authority |
| Goods | Commissioner of Customs, or SEZ Development Commissioner |
| Services other than software | Authorised Dealer (AD) bank, or SEZ Development Commissioner |
| Software | AD bank, or STPI, or SEZ Development Commissioner |
Goods at EDI ports
No separate filing. File the shipping bill on ICEGATE and the EDF is treated as submitted with it. Goods at non-EDI ports: the specified authority forwards the authenticated EDF to your AD bank. Services and software through STPI or an SEZ authority: that authority forwards the authenticated EDF to your AD bank.
Which bank?
File with the AD bank where your export payments finally settle. Banks are still finalising templates, channels (branch, email or portal) and supporting documents, and are expected to publish their export policy and SOP on their websites. Check your bank's page before you file.
Deadlines and a Worked Example
| Export type | When to file |
| Goods | At the time of export |
| Services (non-software) | Within 30 days from the end of the month in which the invoice is raised; may also be filed on or before receipt of payment |
| Software | Within 30 days from the end of the month in which the invoice is raised (no payment-date option) |
The AD bank may extend the period if it is satisfied that the delay has a valid reason.
How to file the EDF for services: step by step?
- Keep a monthly invoice register with invoice number, date, currency, amount and client details.
- Tag each service with its SAC code. Use the same code as in your GST invoices and keep it consistent with the purpose code on your remittance.
- Prepare one EDF for the month. Service exporters fill Part 1 (general information) and Part 2B (export value of services), leaving goods and shipping fields blank. PAN is mandatory; GSTIN and IEC are not mandatory for a services EDF.
- Sign the declaration as exporter or authorised signatory.
- Submit it to your AD bank (or STPI / SEZ authority) before the due date, in the manner your bank specifies.
- Track realisation. The bank enters the EDF in EDPMS within 5 working days, matches your inward remittance and closes the entry once the full value is received.
Realisation Period and the Rs 10 Lakh Relief
The EDF opens a receivable that must be closed. Export value is to be realised within nine months of the invoice date, or twelve months where the export is invoiced or settled in Indian rupees. These periods were set by the 22 September 2026 amendment; guides published earlier may still quote 15 and 18 months, so verify before advising clients.
For a bill or invoice up to Rs 10 lakh, the AD bank can close the EDPMS entry on the exporter's self-declaration of realisation. Please note this is a closure relaxation. It is not an exemption from filing the EDF, and the limit applies per bill, not on annual turnover.
Common Mistakes To Avoid
| Mistake | Fix |
| Counting 30 days from the invoice date | Count from the end of the invoice month |
| Filing one EDF per invoice | Consolidate the month's invoices into one EDF |
| Missing or inconsistent SAC codes | Map every service to a SAC code with your CA in advance |
| Treating the FIRA/FIRC as the EDF | The remittance advice proves money came in; the EDF declares the export |
| Skipping the EDF because payment already arrived | Declaration and receipt are separate obligations |
| Assuming "services" when the export is "software" | Designs, drawings, audio and video can count as software |
| Filing with a bank other than the one where proceeds settle | Use the AD bank that receives the remittance |
What if you do not file?
An inward remittance with no matching EDF leaves a gap in EDPMS against your PAN, and your AD bank is required to follow up until the position is regularised. Non-compliance with FEMA provisions can attract proceedings under Section 13 of the Foreign Exchange Management Act, 1999, depending on the facts. Some banks may also hold back inward remittances where the declaration is overdue, so file on time.
EDF Compliance Checklist for CAs and Exporters
- Classify each client as goods, services or software exporter.
- Confirm whether the client is an individual with personal-nature transactions or a business.
- Build a monthly invoice register with SAC codes.
- Collect your AD bank's EDF template, channel and document list.
- Set a calendar reminder for the 30th of every month for the previous month's invoices.
- Reconcile EDPMS entries with remittances every quarter and watch the realisation deadline.
FAQs
What is the Export Declaration Form (EDF)?
The EDF is a declaration under FEMA in which an exporter states the full export value of goods, services or software. From 1 October 2026 it is a single form covering all three, under the FEMA (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB).
Who must file the EDF from 1 October 2026?
Exporters of goods, services and software. Service exporters, including software exporters, now file an EDF in this form. On 7 October 2026 RBI clarified that individuals are not covered for transactions of a personal nature; RBI has promised FAQs on the exact scope.
Where do I submit the EDF?
Service exporters submit it to their AD bank or, for SEZ units, the Development Commissioner. Software exporters can also use STPI. For goods, the EDF is deemed submitted with the shipping bill at EDI ports; at non-EDI ports the authenticated EDF is forwarded to the exporter's AD bank.
What is the deadline for filing the EDF for services?
Within 30 days from the end of the month in which the invoice is raised. For October 2026 invoices, the due date is 30 November 2026. Non-software service exporters may also file on or before receipt of payment, and the AD bank can extend the period for a valid reason.
Is SOFTEX still required?
No, for software exports made on or after 1 October 2026. The EDF replaces SOFTEX, and software is treated as a service under the 2026 Regulations.
Do freelancers need to file an EDF?
RBI has said individuals are not covered for transactions of a personal nature. A freelancer who invoices overseas clients through a firm, proprietorship or GST registration should confirm the position with their CA and AD bank until RBI publishes its FAQs.
Can one EDF cover several invoices?
Yes. A service exporter can file a single EDF covering all export invoices and overseas customers for the month.
What is the time limit to realise export proceeds?
Nine months from the invoice date, or twelve months where the export is invoiced or settled in Indian rupees, as revised by the amendment of 22 September 2026. Older guides may still show 15 and 18 months.
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