FEMA 23(R)/2026-RB  ·  Effective 1 October 2026

Form EDF for service exporters, explained.

The Reserve Bank of India now requires Indian businesses that invoice foreign clients for services to file an Export Declaration Form with their bank. This guide explains who must file, when it is due, and what the form contains.

Read the questionsOverview
30 days
Deadline: 30 days from the end of the month in which the invoice was raised.
9 months
Time to receive payment from the invoice date, or 12 months if invoiced or settled in INR.
₹10 lakh
Invoices up to this value can be closed on the exporter's own declaration. This is not a filing exemption.
One form
A single EDF can cover every service invoice raised in a month, across clients.
Overview

The requirement in three parts

The EDF is a foreign-exchange declaration under the Foreign Exchange Management Act, 1999. It is not an income tax form, and it is separate from GST.

I.

Invoice

Every service invoice to a foreign client dated on or after 1 October 2026 is covered: consulting, design, IT, marketing, software and others. Record the SAC code and the invoice currency.

II.

Declare

File one consolidated EDF for the month with your Authorised Dealer (AD) bank within 30 days of month-end. Software exporters can file with STPI instead, and SEZ units file with the Development Commissioner.

III.

Realise

Receive full payment within nine months. Your bank matches each incoming payment to your EDF. For invoices up to ₹10 lakh, you can close the entry with your own declaration.

Questions & Answers

Frequently asked questions

The rules are new, and banks are still publishing their procedures. We will revise these answers when RBI publishes its FAQs.

The basicsWhat is Form EDF?

EDF stands for Export Declaration Form. Goods exporters have used it for years. Under the RBI's Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification FEMA 23(R)/2026-RB), service exporters must file it too from 1 October 2026.

The form records the full value of each export invoice. Your bank uploads it to RBI's Export Data Processing and Monitoring System (EDPMS), which then tracks whether the money arrives in India on time.

The basicsIs EDF an income tax form?

No. EDF is a foreign-exchange (FEMA) declaration filed through your bank. You don't file it with the Income Tax Department, and it doesn't change your ITR. Your GST filings and Letter of Undertaking (LUT) for zero-rated exports also continue as before. The same invoices simply feed all three.

Who filesWho has to file an EDF?

The regulations apply to every exporter of services, with no turnover or invoice-value threshold. That includes companies, LLPs, partnership firms, IT/ITES firms, agencies, consultants, SaaS businesses and global capability centres.

The open question is individuals. See the next question.

Who filesI'm a freelancer or sole proprietor. Do I need to file?

It isn't settled yet. Two readings exist:

  • The regulation text has no exemption, and many compliance guides list freelancers, designers, developers and content creators as covered.
  • RBI's clarification of 7 October 2026. Deputy Governor Rohit Jain said:
"…the individuals are not included with respect to the reporting requirements for the contracts of a personal nature."

Governor Sanjay Malhotra gave tutoring and small software work as examples of things individuals need not report. RBI has said it will publish FAQs. Until then, ask your bank how it is treating your account. If your bank holds foreign payments until an EDF is filed, filing is the practical way to get paid.

Who filesDo invoices raised before 1 October 2026 need an EDF?

No. The new requirement depends on the invoice (export) date. Invoices dated before 1 October 2026 don't need an EDF, even if the payment arrives later. Software exports dated September 2026 still use the old SOFTEX form.

Who filesDoes EDF replace SOFTEX for software exports?

Yes. For software exports made on or after 1 October 2026, SOFTEX is replaced by the common EDF. You can file it with your AD bank or with STPI. STPI certification is no longer mandatory.

FilingWhen is the EDF due?

Within 30 days from the end of the month in which the invoice was raised.

Invoices raised inEDF due by
October 202630 November 2026
November 202630 December 2026
December 202630 January 2027
January 20272 March 2027

Exporters of non-software services may also file on or before the date payment is received. It's unclear whether this replaces the 30-day limit, so treat 30 days as the outer limit. Your bank can extend the deadline if you ask with reasons.

FilingWhere and how do I submit it?
  • Non-software services: your Authorised Dealer (AD) bank.
  • Software: your AD bank, or STPI (which forwards it to your bank).
  • SEZ units: the SEZ Development Commissioner.

There is no central government portal. Each bank publishes its own procedure, which may be a net-banking upload, an email or a branch visit. File with the bank where the foreign payment is finally credited. The bank must upload your EDF to EDPMS within 5 working days.

FilingCan I file one EDF for many invoices?

Yes. One EDF can cover all services exported in a month, across one or more foreign clients, with one row per invoice in the services table (Part 2B). You can also file invoice by invoice if you prefer.

FilingWhat information goes into the form?

Part 1 – General

  • Type of export: Service (also for electronically delivered software)
  • PAN (mandatory): your entity's PAN, or your own PAN if you are a proprietor
  • AD code and bank name
  • Mode of delivery: usually Internet for digital work
  • GSTIN and IEC: on the form, but not mandatory for services
  • Total value in INR (no exchange rate is prescribed, so use a reference rate and keep your working)

Part 2B – One row per invoice

  • Client name, address and country
  • Invoice number, date, currency and amount
  • Net realisable value (usually the invoice value)
  • Description of service and SAC code (mandatory)
  • Contract reference (optional)

Section 4 is your signed declaration and undertaking to receive the full value within the realisation period. Section 5 is filled in by the bank.

FilingWhich SAC code should I use?

Use the same Services Accounting Code (SAC) you would use for GST. Common ones:

SACService
998311Management consulting
998312Business consulting (incl. PR)
998313IT consulting and support
998314IT design and development
998361Advertising services
998371Market research
998391Specialty design
FilingWhat is an AD code and where do I find mine?

An Authorised Dealer (AD) code identifies the bank branch authorised to handle your foreign exchange transactions. Not every branch has one. Ask your bank's forex or trade desk for the AD code linked to the account where your export payments land.

FilingDo I need a GSTIN or an Import Export Code (IEC)?

Both fields appear on the form, but neither is mandatory for service exports. PAN is. If you aren't GST-registered, use whatever "not applicable" entry your bank accepts. Never enter someone else's GSTIN.

PaymentsI get paid through Skydo, Wise, Payoneer, Xflow or similar. What changes?

You still file the EDF with the AD bank where the money is finally settled, which may not be the bank named on your platform's FIRA. Some platforms are adding EDF help: Xflow, for example, lets you file when you withdraw. Keep your FIRA, because the bank will use it to match the payment to your EDF.

PaymentsHow long do I have to receive payment?

Nine months from the invoice date, or twelve months if the invoice is in, or settled in, Indian Rupees. These limits were shortened from 15 and 18 months by the 22 September 2026 amendment. Your bank can extend them if you ask with reasons.

If payment stays outstanding for more than a year past the due date, further exports are allowed only against full advance payment or an irrevocable letter of credit.

PaymentsMy invoices are small (under ₹10 lakh). Am I exempt?

No. ₹10 lakh is not a filing exemption. For invoices up to ₹10 lakh, your bank can close the EDPMS entry on your simple self-declaration that payment was received, and quarterly bulk declarations are allowed. The bank can also accept a reduced value of up to ₹10 lakh per invoice on your declaration, for example when a client underpays. Larger invoices need supporting documents.

PenaltiesWhat happens if I don't file?

Not filing is a contravention of FEMA section 7. Under section 13, the penalty can be:

  • up to three times the sum involved, where it can be quantified, or up to ₹2 lakh where it can't
  • plus up to ₹5,000 per day while the contravention continues

You can apply for compounding under section 15. The practical risk comes sooner: payments without a matching EDF can be held or delayed by the bank, and missing realisation evidence can hurt GST refund claims.

PaymentsWill my bank charge me for this?

Banks can't penalise you for regulatory delays, but they may charge normal processing fees. Charges vary by bank, so ask before you submit. Banks may agree to reduce or waive the fee.

About this siteIs formedf.com an official RBI or government website?

No. formedf.com is an independent guide and isn't affiliated with RBI, the Government of India or any bank. This page is general information, not legal or tax advice. Always check the official sources or ask your bank or a chartered accountant.

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References

Sources

Official RBI documents are listed first. Please tell us if anything here is out of date.