Short answer. If you raise an invoice dated on or after 1 October 2026 to a client outside India for a service, expect to file an EDF with the bank that receives your foreign payments, within 30 days from the end of that invoice's month. There is no minimum amount. One EDF can cover the whole month. October 2026 invoices are due by 30 November 2026. Want a verdict on one invoice? Run the free EDF checker.
What changed on 1 October 2026
RBI replaced the 2015 export regulations with the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, notified as FEMA 23(R)/2026-RB on 13 January 2026, amended on 22 September 2026 and in force from 1 October 2026. For anyone selling services abroad, four things are new in practice.
- Services get a declaration. Exports of services are declared on the same EDF annexed to the regulations that goods use, through dedicated service parts of the form.
- Softex is folded in. Software is treated as a service, so the separate Softex form is no longer prescribed. Details are in Softex vs EDF.
- A monthly rhythm. One EDF can cover every service export invoice of a calendar month, across all your clients.
- Banks track it. Your AD bank enters each EDF in EDPMS, RBI's Export Data Processing and Monitoring System, and closes it once the money is in.
The trigger is the invoice date. An invoice dated 28 September 2026 sits under the old framework even if the client pays in November. An invoice dated 2 October 2026 is in the new cycle even if the work was done in September.
Who must file
The regulations apply to persons resident in India exporting services, and they set no value or turnover threshold. In practice that reaches most people who bill overseas clients as a business:
- Freelance developers, designers, writers, editors and consultants who invoice foreign clients
- Agencies and studios, whether proprietorships, partnerships, LLPs or companies
- SaaS and software businesses billing overseas customers, including subscriptions
- IT-enabled services, BPO and KPO providers, and professional firms with foreign clients
- Creators who invoice foreign brands directly for sponsored work
Creator income from platform revenue sharing, such as YouTube AdSense, is harder to classify because there may be no invoice from you to a foreign recipient. That gets its own careful treatment in the YouTubers guide (coming soon), and you should not assume either way until your bank confirms.
Not sure where you land? The checker walks through invoice date, client location and type of service.
RBI's 7 October clarification for individuals
On 7 October 2026, RBI publicly said that individuals receiving payments under contracts of a personal nature are not covered by the export reporting requirement, that the ₹10 lakh self-declaration operates per bill, and that FAQs will follow. Several business publications reported the remarks the same day.
[Disclaimer] This rests on press reports of RBI's remarks, not on a published circular or FAQ. Confirm the exact wording and link the RBI source once available. Until then, do not read "personal nature" as covering every freelancer. A sole proprietor who issues commercial invoices, uses a GSTIN or LUT, or runs an agency is more likely to be treated as a business exporter.
Until the FAQs land, the safe approach is simple. If your bank asks for an EDF, file it; filing when you turn out not to need it costs little, while missing one you did need is a compliance gap. The freelancers guide (coming soon) will track this as RBI publishes detail.
What the EDF contains
The form annexed to the regulations has several parts. Service exporters usually complete three of them and leave the goods and shipping fields blank.
| Part | What you enter |
|---|---|
| Part 1 | Exporter details: export type, delivery mode, AD code, PAN, IEC and GSTIN if you have them, realisation mode, any third-party payer, and the month's total |
| Part 2B | One row per invoice: client name, address and country, invoice number and date, currency and amount, description of the service and SAC code |
| Part 4 | Your declaration, the date by which you expect the money, and signature |
| Part 5 | Filled by the bank |
For a step-by-step walk-through, read How to file an EDF with your bank. A field-by-field sample with a downloadable template is planned for that guide.
When to file
File within 30 days from the end of the month in which the invoice was raised. Counting 30 days rather than "one month" matters: November invoices are due on 30 December, and January invoices on 2 March.
| Invoices dated in | EDF due by |
|---|---|
| October 2026 | 30 November 2026 |
| November 2026 | 30 December 2026 |
| December 2026 | 30 January 2027 |
| January 2027 | 2 March 2027 |
| February 2027 | 30 March 2027 |
| March 2027 | 30 April 2027 |
Software vs other services
| Software exporters | Other service exporters | |
|---|---|---|
| Standard deadline | 30 days from month-end | 30 days from month-end |
| Option to file on or before the payment date | Not available | Available |
| Extension on a reasoned request to the AD bank | Yes | Yes |
"Software" is defined broadly, covering programs, databases, drawings, designs, audio or video signals and information delivered on a non-physical medium. Designers and video editors who deliver files can fall on the software side. The software-definition guide (coming soon) goes deeper; for now see Softex vs EDF.
Where to file
There is no RBI portal for individual uploads. You file with your specified authority, which then enters the EDF in EDPMS.
| Your situation | File with |
|---|---|
| Services other than software, outside an SEZ | Your Authorised Dealer (AD) bank |
| Software, outside an SEZ | Your AD bank or STPI |
| Unit in a Special Economic Zone | The SEZ Development Commissioner |
Your AD bank is normally the one where export money finally lands, which may not be the bank named on a platform's remittance advice. The bank has five working days from receipt to enter a services EDF in EDPMS.
The monthly routine
Once the one-time setup is done, the cycle takes an hour or two a month for most small exporters.
Set up once
- Pick one receiving bank for foreign payments where you can, and note its AD code, which differs from the IFSC or SWIFT code.
- Get the bank's EDF process in writing: format, channel, documents and any charges.
- Map each service to a SAC code for the form and an RBI purpose code for the inward remittance, and keep both consistent with your GST filings.
- Fix your invoice template with a unique number, date, currency, client legal name, address and country, and a plain description of the service.
Every month
- List every export invoice dated in the month.
- Fill Parts 1, 2B and 4 with one Part 2B row per invoice.
- Attach what the bank asks for, usually invoices and a contract or statement of work.
- Submit within 30 days of month-end and keep the acknowledgement.
- Confirm the bank has entered it in EDPMS.
- As payments arrive, match them to invoices and ask the bank to close the entries.
The freelancers guide (coming soon) turns this into a checklist you can keep in a spreadsheet.
Closing entries and the ₹10 lakh self-declaration
Filing opens an EDPMS entry for each invoice. The bank closes it once it is satisfied the money has been realised. For any invoice up to ₹10 lakh, your own declaration that payment was received in full or otherwise can be enough, and one declaration per quarter can cover many invoices.
- The limit applies per invoice, not per month, client or year.
- It simplifies closure only. You still file the EDF.
- Above ₹10 lakh, expect to give remittance evidence such as a FIRA or bank advice so the bank can match the payment.
A dedicated guide to the self-declaration and quarterly bulk closure, with a sample declaration, is coming soon.
Realisation and unpaid invoices
After the 22 September 2026 amendment, export value should ordinarily be realised within 9 months from the invoice date, or 12 months where the invoice is raised or settled in Indian rupees. Articles quoting 15 or 18 months are out of date.
- Running late? Ask your AD bank for an extension before the period runs out.
- Client paid less? Reductions, discounts and write-offs have their own route under the regulations. Talk to your bank rather than leaving the entry open.
- Dead invoices: if proceeds stay unrealised for more than a year beyond the due date, further exports to that client may be allowed only against full advance payment or an irrevocable letter of credit.
[Disclaimer] CA to confirm the regulation numbers and the exact write-off limits to cite here before publish. A full guide to extensions, write-downs and Regulation 13 is coming soon.
Banks and payment platforms
Every AD bank sets its own EDF format, channel and charges, and must publish its policy. Expect differences in whether a bank wants an IEC, how it classifies software, and what it charges for handling. FEMA does not make an IEC a condition for exporting services, though some banks still ask for one.
If you are paid through Wise, Skydo, Xflow, Razorpay or Payoneer, file with the bank that actually receives the payout into India. Platforms differ on whether they want the EDF before releasing funds, so get their process in writing.
[Disclaimer] No bank fees or platform procedures are stated here because none have been verified. The bank-by-bank tracker and the platforms guide (both coming soon) will only list figures confirmed from each bank's or platform's own published policy.
EDF vs FIRA vs purpose code vs LUT
These get confused because they all touch the same invoice. They are separate records and should tell the same story.
| Record | What it is | Who creates it |
|---|---|---|
| EDF | Your FEMA declaration of the export | You, filed with the AD bank |
| FIRA or bank advice | Proof that foreign money arrived | The bank, or a platform's partner bank |
| Purpose code | RBI code describing why the money came in | Chosen by you or the bank at inward remittance |
| LUT | GST undertaking that lets you export without paying IGST | You, on the GST portal, once a financial year |
| e-BRC | Electronic realisation certificate on DGFT's system | Generated from bank data |
[Disclaimer] GST and LUT conditions for export of services are held for CA review in a separate guide and are summarised here only at a high level. Confirm the e-BRC description before publish.
Late filing and penalties
The regulations set no specific late fee for an EDF, and banks may not penalise you for a regulatory delay, although their usual handling charges can still apply. The general penalty provisions of FEMA still sit behind every requirement, and contraventions can be compounded through RBI. If a deadline is near, ask your bank for an extension before it passes.
[Disclaimer] CA to confirm whether to cite the FEMA Section 13 penalty ranges here, or keep the general statement above.
What to focus on, by type of exporter
Freelancers
Work out first whether you are an individual on a personal-nature contract or a business exporter, then set up one receiving bank and a monthly habit. The ₹10 lakh per-invoice closure will cover most of your invoices.
Agencies and studios
Expect more clients, more invoices and more partial payments. Keep a running register that links each invoice to its EDF, remittance and purpose code, and decide early whether your design or video work counts as software.
Creators
Direct brand deals invoiced to foreign companies look like ordinary service exports. Platform payouts such as AdSense need careful classification, so wait for your bank's view and the RBI FAQs.
SaaS and software companies
You are on the software track, so the file-on-payment option does not apply and the 30-day deadline is firm. High-volume subscription billing makes the monthly single-EDF rule and clean SAC and purpose-code mapping essential.
All EDF guides
Each step above has its own deeper guide. Live guides are linked; the rest are on the way.
FAQs
Is there a minimum invoice value below which no EDF is needed?
No. There is no value or turnover threshold for filing. The ₹10 lakh figure only simplifies closure after payment.
When is the first EDF for services due?
October 2026 invoices are due by 30 November 2026.
Where do I file?
With your AD bank. Software exporters outside an SEZ can also use STPI, and SEZ units file with the Development Commissioner.
Do freelancers have to file?
Freelancers billing foreign clients as a business generally do. RBI said on 7 October 2026 that individuals on personal-nature contracts are not covered and that FAQs will follow, so check with your bank until then.
How long do I have to bring the money in?
Ordinarily 9 months from the invoice date, or 12 months for invoices raised or settled in rupees.
Is the EDF the same as a FIRA or an LUT?
No. The EDF declares the export, the FIRA proves money arrived, and the LUT is a GST filing. You usually need all three, and they should reconcile.
Next step
Check one real invoice in the free checker, then set up your bank's EDF process before 30 November 2026.
Sources and limits
Based on the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification FEMA 23(R)/2026-RB), notified 13 January 2026 and amended 22 September 2026, and on press reports of RBI's 7 October 2026 remarks pending its FAQs. This is a guide, not legal advice. Confirm format, channel and charges with your AD bank or a CA before you file.