Short answer. For any service invoice of up to ₹10 lakh (or the foreign-currency equivalent), your bank may close the EDPMS entry on your declaration that payment was realised in full or otherwise. You can give that declaration quarterly, for many invoices at once. The limit is per invoice, not per month or year, and it does not remove the monthly EDF. Not sure you need to file at all? Run the free EDF checker.
What the rule says
Filing an EDF opens one EDPMS entry per invoice. Under Regulation 4(2) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, your AD bank marks an entry off once it is satisfied the export value has been realised. The first proviso adds a shortcut for small invoices:
"…in the case of export where the shipping bill (for goods) or invoice (for services) is up to ₹10 lakh (or its equivalent in foreign currency), entry in EDPMS may be closed based on a declaration from the exporter to the effect that the payment against the shipping bill / invoice has been realised either in full or otherwise. Alternatively, such declaration may be submitted by an exporter to the Authorised Dealer on a quarterly basis for bulk closure of entries in EDPMS."
Three things follow from that wording:
- Per invoice. The test is each invoice's value. On 7 October 2026 RBI Governor Sanjay Malhotra put it as "not annually, per bill" (see our RBI update).
- "In full or otherwise". The declaration can cover invoices that were paid short, not only those paid in full.
- Two ways to submit. Invoice by invoice as money arrives, or one consolidated declaration each quarter.
This is not new in spirit. RBI first allowed banks to close entries of up to ₹10 lakh per bill on the exporter's declaration, with quarterly consolidated declarations, through A.P. (DIR Series) Circular No. 12 of 1 October 2025. From 1 October 2026 that relief sits directly in the Regulations.
What it does not do
| Common belief | What the rules actually say |
|---|---|
| "Invoices under ₹10 lakh don't need an EDF." | Wrong. If you are in scope, every invoice goes on the monthly EDF, due within 30 days from the end of the invoice month. See EDF due dates. |
| "I'm under ₹10 lakh a year, so I'm exempt." | Wrong. The limit is per invoice, and it governs closure, not whether you file. |
| "The declaration extends my realisation deadline." | No. Money should still be realised within 9 months of the invoice date (12 months for invoices raised or settled in rupees) after the 22 September 2026 amendment. |
| "I can stop keeping FIRAs or bank advices." | Keep them. The bank may still ask, and your GST and income-tax records need them anyway. |
| "It's an RBI portal I file myself." | No. You give the declaration to your AD bank, which closes the entries in EDPMS. |
Freelancers: RBI also said on 7 October that individuals paid under contracts of a personal nature are outside the reporting requirement. If that is you, check EDF for freelancers before worrying about closure at all.
Does this invoice qualify?
Enter an invoice amount and the rupee rate your bank uses. Everything runs in your browser; nothing is sent anywhere.
No default rate is filled in on purpose. The regulations don't say which conversion rate applies, so use the one your bank confirms.
Enter a rate to see the result.
An invoice of exactly ₹10 lakh still qualifies ("up to"). Split invoices deserve care: the limit is genuinely per invoice, but breaking one engagement into several bills only to stay under it may draw questions from your bank. [Disclaimer] Banks may apply their own review to invoices they see as split.
Quarterly bulk closure, step by step
- Keep filing monthly. The EDF for each invoice month is unchanged. Closure happens later.
- Keep one invoice register. Invoice number, date, currency, amount, rupee equivalent, EDF month, date paid, amount received and the bank reference. The how to file guide explains the EDF fields the register should match.
- Flag qualifying invoices. Up to ₹10 lakh each, with money realised in full or in part during the quarter.
- Get your bank's format. Ask whether it wants invoice-wise or quarterly declarations, on letterhead or its own form, by email, branch or net-banking.
- Send one declaration after the quarter ends. List every qualifying invoice with the amount realised and sign it.
- Get confirmation. Ask the bank to confirm the entries are closed. Anything still open is your follow-up list for next quarter.
[Disclaimer] The Regulations say "on a quarterly basis" without defining the quarter or a cut-off. Most banks are likely to use financial-year quarters (Apr–Jun, Jul–Sep, Oct–Dec, Jan–Mar), but confirm your bank's quarter and submission window before relying on it.
Example (illustrative, not real data)
A two-person design studio bills three overseas clients in October and November 2026 and files an EDF for each month. By December all invoices are paid:
| Invoice | Value | Received | Closure route |
|---|---|---|---|
| INV-101 (Oct) | USD 3,000 | USD 2,985 (fee deducted abroad) | Quarterly declaration, "otherwise" |
| INV-102 (Oct) | GBP 1,800 | GBP 1,800 | Quarterly declaration, in full |
| INV-103 (Nov) | USD 14,000 | USD 14,000 | Over ₹10 lakh at most rates, so remittance evidence to the bank |
One Oct–Dec declaration closes INV-101 and INV-102. INV-103 goes through the bank's normal matching with a FIRA or bank advice.
Short payments and write-downs
Clients pay less for all sorts of reasons: intermediary bank fees, an agreed discount, a disputed milestone, a client who never pays. Regulation 6 lets the AD bank allow a reduction in export value when it is satisfied of your reasons. Its proviso eases this for small invoices: up to ₹10 lakh per invoice, a reduction, including non-realisation of the full value, may be permitted on your own declaration.
In practice, add a "shortfall and reason" column to the quarterly declaration so the bank can close the entry at the reduced value in one go. Keep the email trail or credit note that explains the shortfall.
[Disclaimer] Whether a fully unpaid invoice can be closed through the quarterly declaration alone, or needs a separate Regulation 6 request, may vary by bank. A full guide to unpaid invoices, extensions and write-downs is coming soon.
Declaration template
Banks set their own formats, so treat this as a starting point and replace it with your bank's form if it has one.
Prefer a file? Download the declaration template (.txt) and edit it in any text editor.
Invoices above ₹10 lakh
The declaration route doesn't apply. Expect the bank to match the remittance to the invoice using the FIRA or bank advice, and to ask for reasons and documents for any shortfall before allowing a reduction. Using one receiving bank and quoting the invoice number on every payment makes this matching much faster.
Paid through Wise, Skydo, Payoneer or a similar platform? File and close with the bank that actually receives the payout in India, and keep the platform's settlement statement with your register.
If a bank charges you for a delay, note that Regulation 19(3) bars an AD bank from levying any charge or penalty on the exporter for a regulatory delay or violation. Normal handling charges in the bank's published policy can still apply.
FAQs
Is ₹10 lakh a threshold below which I don't need to file an EDF?
No. The ₹10 lakh figure is a closure rule, not a filing threshold. If your services are in scope, every invoice still goes on the monthly EDF. The self-declaration only lets the bank close the EDPMS entry for an invoice of up to ₹10 lakh on your word, after payment, instead of matching remittance documents.
Is the ₹10 lakh limit per invoice, per month or per year?
Per invoice (per bill). The regulation applies it to each invoice for services, and RBI Governor Sanjay Malhotra said on 7 October 2026 that it is per bill, not annual. A month with twenty invoices of ₹2 lakh each is still twenty invoices that can each be closed by declaration.
What does quarterly bulk closure mean?
Instead of declaring invoice by invoice, you may give your AD bank one declaration each quarter that lists every invoice up to ₹10 lakh whose payment was realised, in full or otherwise, so the bank can close those EDPMS entries together.
What if the client paid less than the invoice?
The declaration can say payment was realised 'in full or otherwise'. For invoices up to ₹10 lakh, a reduction in export value, including non-realisation, may also be allowed on your own declaration under Regulation 6. Above ₹10 lakh, the bank has to be satisfied with your reasons.
Which exchange rate decides whether an invoice is under ₹10 lakh?
The regulations say ₹10 lakh or its equivalent in foreign currency but do not name a conversion rate. Ask your AD bank which rate it uses; invoices close to the limit are where this matters.
Can my bank charge a penalty if I close entries late?
The regulations bar an AD bank from levying a charge or penalty on the exporter for a regulatory delay or violation. Normal service or handling charges set in the bank's own policy can still apply.
Next step
Start the invoice register now, ask your bank this week how it wants the quarterly declaration, and keep filing each month's EDF on time.
Sources and limits
Based on the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification FEMA 23(R)/2026-RB, RBI text), notified 13 January 2026 and amended 22 September 2026: first proviso to Regulation 4(2) (closure on declaration and quarterly bulk closure), proviso to Regulation 6 (reduction on declaration up to ₹10 lakh), Regulation 5(1) (realisation period) and Regulation 19(3) (no penalty for regulatory delay). Background on A.P. (DIR Series) Circular No. 12 of 1 October 2025 and the Governor's 7 October 2026 remarks is from public reporting. This is a guide, not legal advice. Confirm formats, quarters and conversion rates with your AD bank or a CA.