Companion pieces: the step-by-step setup is in Your first EDF is due on 30 November, the import side of the same regulations in The other half of FEMA 2026, and the EDF filing helper works out every deadline from your invoice list.
If you invoiced a foreign client on or after 1 October 2026 — a design retainer, a consulting engagement, a SaaS subscription, an export of software — you now have a filing obligation you probably did not have last month. Under the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB dated 13 January 2026, in force from 1 October 2026), every exporter of services must declare that invoice on an Export Declaration Form within 30 days of the end of the month in which it was raised.
Goods exporters have filed EDFs for years — it happens automatically with the shipping bill. What changed on 1 October is that services and software came into the same form, and SOFTEX, the form software exporters filed through STPI, is gone.
What exactly changed
The 2026 regulations supersede the Export of Goods & Services Regulations, 2015 outright — not as an amendment, but as a replacement, along with the circulars built on top of them. Three things matter for anyone selling services abroad:
| Before 1 October 2026 | From 1 October 2026 |
|---|---|
| Non-software services: no routine declaration form; banks captured the inward remittance | Every service invoice is declared on an EDF |
| Software exports: SOFTEX, usually certified by STPI | One EDF, which an AD bank can certify — STPI remains an option, not a requirement |
| Separate frameworks for goods, software and services | A single declaration framework for all three |
The form is filed with what the regulations call the specified authority (Regulation 2(f)):
- Services other than software, in the domestic tariff area — your Authorised Dealer (AD) bank.
- Software, in the DTA — your AD bank or STPI.
- Units in an SEZ — the Development Commissioner of the SEZ.
- Goods — the Commissioner of Customs, as before, via the shipping bill.
That one change — an AD bank can now certify software exports — is the quiet relief in this package. Software exporters outside STPI schemes no longer need a separate registration path just to get a form stamped.
The deadline: 30 days from the end of the invoice month
Regulation 3(2) requires the declaration within 30 days from the end of the month in which the invoice for services has been raised. Note where the clock starts — not from the invoice date, and not from when the client pays.
So for invoices raised at any point in October 2026, the EDF is due by 30 November 2026. November invoices are due by 30 December, and so on. Most banks accept a single EDF covering all of a month's invoices rather than one form per invoice; ask yours which it wants, because the practice is not uniform yet. Some banks also accept a filing for a non-software service invoice at or before the date the payment arrives, if that is earlier.
The trigger is the invoice date, not the payment date. An invoice dated 28 September 2026 that is paid in November falls under the old regime; an invoice dated 2 October that is paid in March falls under the new one.
Counting the deadline around weekends and holidays is easy to get wrong — the business days calculator will give you the exact date.
What the form asks for
An EDF for services is short, but it is specific. Expect to supply:
- Your name, address, PAN, GSTIN and IEC where applicable, and your bank's AD code
- The buyer's name, address and country
- Invoice number, date, currency and value, and the net realisable value
- A description of the service and its SAC code — the six-digit services accounting code; the HSN/SAC finder will give you the right one
- Mode of delivery (for digital services, "internet")
- The contract or purchase-order reference, if there is one
Two practical notes. First, the SAC code on the EDF should match what you put on your invoice — a consulting engagement billed under 9983 should not appear as 9984 on the declaration. Second, foreign-currency invoices need an INR value; use the RBI reference rate for the invoice date, which the currency converter will also show you.
The 9-month clock, and what EDPMS does with it
Filing the EDF creates an entry in EDPMS, the RBI's Export Data Processing and Monitoring System. That entry stays open against your PAN until the money arrives and your bank matches it.
Regulation 5(1) sets the realisation period: nine months from the date of invoice for services (nine months from the date of shipment for goods, or from the date of sale out of a warehouse), extended to twelve months where the export is invoiced in Indian rupees. Project exports follow the payment terms of the contract.
When the remittance lands, the bank generates an Inward Remittance Message, matches it to the open EDF entry, closes it, and issues the eBRC — the electronic Bank Realisation Certificate that proves the export proceeds came in. That certificate is what you need for GST refund claims on zero-rated exports and for export incentive schemes.
The sequence, end to end: invoice → EDF within 30 days of month-end → bank posts it to EDPMS → client pays → bank matches the remittance → entry closed → eBRC issued.
The ₹10 lakh relief
For small invoices, the paperwork is lighter. Under A.P. (DIR Series) Circular No. 12 of 1 October 2025, AD Category-I banks may close EDPMS entries of ₹10 lakh or less per entry on the exporter's own declaration that the money has been realised — no further documentary proof — and those declarations can be submitted quarterly in a consolidated format. The same ₹10 lakh threshold runs through Regulation 6 of the 2026 regulations for reducing the declared export value on a self-declaration.
Above ₹10 lakh, expect your bank to ask for the invoice, proof of payment and the FIRA or FIRC from the receiving bank before it closes the entry.
The same circular told banks to review their charges in line with the simplified process and barred them from levying penal charges for delays that were the bank's own. Worth knowing if a relationship manager quotes a fee for "regularising" an entry.
What happens if you ignore it
Nothing, for a while — and that is the trap. The consequences arrive later and all at once:
- Open EDPMS entries pile up against your PAN. Every unfiled invoice is an unreconciled export in the RBI's system.
- No eBRC. Without it, a GST refund claim on zero-rated exports stalls, and so does any incentive claim.
- Unmatched inward remittances. Money arrives with no declaration to match it to, and the bank starts asking questions months after the fact.
- Caution listing. Exporters with persistently overdue entries can be placed on the RBI's caution list, after which further exports need prior bank approval — a serious problem if exports are your only revenue.
- Penalties under Section 13 of FEMA, which allows up to three times the amount involved where it is quantifiable, or up to ₹2 lakh where it is not, plus up to ₹5,000 a day while the contravention continues. Contraventions can be compounded under Section 15, but that is a process and a cost you would rather avoid.
A five-step routine for a small exporter
- Ask your bank today how it wants the EDF — a portal, an email template, or a branch form — and whether it accepts one consolidated form per month. Practice varies widely.
- Keep an export invoice register: invoice number, date, client, country, currency, amount, SAC code, INR value, and the date the money arrived. This is also the sheet your CA will ask for.
- Diarise the 30th of every month for the previous month's filing. For October invoices, 30 November.
- Chase realisation inside nine months. If a client is slow, that is now a FEMA deadline, not just a cash-flow problem — put interest terms on the invoice and follow up early.
- Collect the eBRC after each payment, and keep the FIRA for anything above ₹10 lakh.
This sits on top of your GST position, not instead of it
The EDF is a FEMA filing with your bank. It does not replace anything on the GST side: exports of services are still zero-rated, you still file a Letter of Undertaking each financial year to invoice without IGST, and you still count export turnover toward the ₹20 lakh registration threshold. The tax side — 44ADA presumptive taxation, GST on exports, LUT and the invoices foreign clients accept — is covered in Freelancer taxes in India, and what to put on the invoice itself in GST invoice format: the 16 mandatory fields.
If you are pricing export work, build the compliance time and the bank's charges into the rate — the freelance rate calculator has a line for business costs, and the currency converter shows what a 2% bank margin actually takes out of a $2,000 invoice.
FAQ
Who has to file an EDF from 1 October 2026?
Every exporter of services or software from India — freelancers, consultants, agencies, IT and ITeS companies, SaaS businesses, GCCs and captive centres — for invoices raised on or after 1 October 2026. Goods exporters continue to file through the shipping bill.
What is the deadline for filing?
Within 30 days from the end of the month in which the invoice was raised. October 2026 invoices are due by 30 November 2026.
Does EDF replace SOFTEX?
Yes, for exports on or after 1 October 2026. Software exports are declared on the unified EDF, and an AD bank can certify it — STPI remains available as a specified authority but is no longer the only route.
What if my invoice was raised before 1 October but paid after?
The trigger is the invoice date. Invoices dated before 1 October 2026 stay under the previous framework even if the money arrives later.
How long do I have to receive the money?
Nine months from the invoice date for services, or twelve months if the invoice is in Indian rupees. Project exports follow the contract's payment terms.
Do I need to file for small invoices?
The declaration applies regardless of value, but closure is simpler: for entries of ₹10 lakh or less, AD banks can close the EDPMS entry on your own declaration that the amount was realised, and can accept those declarations quarterly in a consolidated format.
What is the penalty for not filing?
Open EDPMS entries against your PAN, no eBRC (which blocks GST refunds on exports), possible caution listing, and penalties under Section 13 of FEMA of up to three times the amount involved, or up to ₹2 lakh where it is not quantifiable, plus up to ₹5,000 a day for a continuing contravention.
Do SEZ units file with their bank?
No. Units in a Special Economic Zone file with the Development Commissioner of the SEZ rather than with an AD bank.