Before you start
Confirm you actually need an EDF for the invoice in front of you. The rule follows the invoice date, not when you did the work or got paid. Invoices dated before 1 October 2026 do not need an EDF under the new cycle even if money arrives later. Use the free EDF checker if you want a one-invoice verdict.
- No minimum invoice value or turnover exemption.
- One EDF can cover every export invoice of a calendar month, across clients.
- Software exporters cannot use the “file on payment day” shortcut that other service exporters get.
Due dates (30 days, not “one month”)
File within 30 days from the end of the month in which the invoice was raised. November invoices are due on 30 December, not 31 December.
| Invoices raised in | EDF due by |
|---|---|
| October 2026 | 30 November 2026 |
| November 2026 | 30 December 2026 |
| December 2026 | 30 January 2027 |
| January 2027 | 2 March 2027 (30 days from 31 Jan → 2 Mar) |
Exporters of services other than software may instead submit the EDF on or before the date payment is received. Your AD bank may also extend the filing period on a request that gives reasons (Regulation 3(2)(c)).
One-time setup with your AD bank
- Identify the AD bank. It is the bank where your export money is finally credited — not necessarily the bank printed on a platform FIRA. Note the bank’s AD code (different from IFSC or SWIFT).
- Get the SOP in writing. Ask the forex team for EDF format, submission channel (branch / email / net-banking, if any), document checklist and charges. Every AD bank must publish its policy on its website.
- Ask the awkward questions early. Will it accept a services EDF on PAN alone, or does it insist on an IEC? Does it treat your work as software? Does it close invoices up to ₹10 lakh on a quarterly self-declaration?
- Map codes. Each service needs a SAC (for the form) and, when money arrives, an RBI purpose code that matches. Keep them consistent with GST and your invoice description.
- Fix the invoice template. Unique number, date, currency, amount, client’s legal name, address and country, and a clear description of the service.
[REVIEW / UNKNOWN] Do not hard-code any bank’s email address, portal URL or fee table here — those change and are not in the FEMA text. Link only to the bank’s own published forex policy once verified.
Every month: fill and submit
- List every export invoice raised in that calendar month.
- Fill the EDF annexed to the regulations. Service exporters typically complete Part 1, Part 2B (one row per invoice) and Part 4 (declaration and signature). Leave goods/shipping fields blank.
- Attach what your bank’s SOP asks for — commonly invoices, contract or SOW, and proof of service. If someone other than the client pays you, declare that third party on the form.
- Submit within the 30-day window and keep acknowledgement or stamp proof.
- Follow up until the bank confirms the entry in EDPMS. The bank has five working days from receipt to enter a services EDF (Regulation 18(1)(b)).
What goes where (quick map)
| Part | You enter |
|---|---|
| Part 1 | Export type (service), delivery mode (often internet for digital work), exporter category, AD code, PAN, IEC/GSTIN if you have them, name and address, realisation mode, third-party payer if any, month’s total in rupees |
| Part 2B | Per invoice: client name, address, country, invoice number and date, currency, amount, net realisable value, contract details if any, description, SAC |
| Part 4 | Declaration, date by which you will bring the money in, signature |
| Part 5 | Filled by the bank |
Closing the entry and the ₹10 lakh rule
Filing opens an EDPMS entry. The bank closes it when it is satisfied the money has come in. For any invoice up to ₹10 lakh, your own declaration that payment was received “in full or otherwise” can be enough, and you may give one declaration per quarter covering many invoices.
- The limit is per invoice, not per month, year or client.
- It does not exempt you from filing the EDF — it only simplifies closure.
- Above ₹10 lakh, expect to give the invoice and remittance evidence (FIRA / bank advice) so the bank can match the remittance.
Realisation window after the 22 September 2026 amendment: ordinarily 9 months from the invoice date, or 12 months if the invoice is raised or settled in rupees. Articles still quoting 15/18 months are outdated.
Paid via Wise, Skydo, Razorpay or another platform
File with the bank that actually receives the platform payout. That may differ from the bank named on a remittance advice. Platforms also differ on whether they want the EDF before releasing funds. Using one receiving bank where you can keeps matching simpler.
[REVIEW] Platform-specific SOPs are outside the FEMA text. Treat any product claim as unverified until the platform and AD bank confirm it in writing.
If you are late or stuck
- Before the deadline: write to the bank with reasons and ask for an extension under Regulation 3(2)(c).
- Late fee: the regulations set none for late EDF filing, and banks are barred from penalising you for a regulatory delay. Handling charges can still apply; general FEMA penalties for non-compliance still exist.
- Long-unpaid invoices: if proceeds stay unrealised more than a year beyond the due date, further exports to that client may be allowed only against full advance or an irrevocable letter of credit — close or write down dead invoices instead of leaving them open.
FAQs
Is there an RBI portal where I upload the EDF myself?
No. You file with your AD bank (or STPI / SEZ Development Commissioner where that is the specified authority). The bank enters the EDF in EDPMS.
When is the first EDF due?
October 2026 invoices: by 30 November 2026.
Can one EDF cover multiple clients?
Yes. Regulation 3(2)(a) lets you submit a single EDF for all service exports in a month, to one or more recipients.
Do I need an IEC?
FEMA does not make an IEC a condition for exporting services or filing the EDF. DGFT requires an IEC for services mainly if you claim Foreign Trade Policy benefits. Some banks may still ask for one — check yours, and obtain an IEC from DGFT if it insists.
Next step
Run the checker for a sample invoice, then book time with your bank’s forex desk 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. This is a guide, not legal advice. Confirm format, channel and charges with your AD bank or a CA before you file.