Compliance
EDF for export of services: what changed on 1 October 2026
Payzoplus team · Published · 3 min read
Written by the Payzoplus team. Not legal or tax advice — confirm with your CA.
From 1 October 2026, every Indian exporter of services — software included — files an Export Declaration Form (EDF) stating the full export value, within 30 days from the end of the month the invoice was raised. You file with your AD Category-I bank (software exporters may use STPI; SEZ units the Development Commissioner). The bank logs it on RBI’s EDPMS, matches it to the payment, and closes the entry.
Who has to file an EDF?
Every exporter of services — not only software firms, as under SOFTEX. The rule is regulation 3(2) of RBI’s Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB of 13 January 2026, amended by FEMA 23(R)/(1)/2026-RB of 22 September 2026), in force since 1 October 2026. The regulations say in terms that "services" includes software, and they set no minimum invoice value.
Where do I file it?
| You export | File the EDF with |
|---|---|
| Services other than software, from the domestic tariff area | Your AD Category-I bank |
| Software, from the domestic tariff area | Your AD bank or STPI |
| Services or software, as an SEZ unit | The Development Commissioner of the SEZ |
| Goods | Customs (deemed filed with the shipping bill at EDI ports), or the SEZ Development Commissioner |
Where the authority is not your bank, it forwards the authenticated EDF to your AD bank.
What is the deadline?
File within 30 days from the end of the month in which you raised the invoice. One EDF can cover every client you invoiced that month. Exporters of services other than software may instead file on or before the date the payment arrives. If you are late, your AD bank can extend the window when you give reasons and it is satisfied they are reasonable.
| Invoice dated | Month ends | EDF due by |
|---|---|---|
| 3 October 2026 | 31 October 2026 | 30 November 2026 |
| 20 November 2026 | 30 November 2026 | 30 December 2026 |
| 8 December 2026 | 31 December 2026 | 30 January 2027 |
How do I file it, step by step?
- Raise the export invoice with the correct date, SAC, currency and purpose code.
- Prepare the EDF with exporter, client and invoice details and the full export value. One form can list all of the month’s invoices.
- Submit it to your AD Category-I bank (or STPI, or the SEZ Development Commissioner) within 30 days of the invoice month-end.
- Receive the payment under the matching purpose code.
- The bank matches the remittance to the EDF on EDPMS — keep the remittance advice on file.
- Once the entry is closed, generate the e-BRC on the DGFT portal if you need one.
What about small invoices?
Where an invoice is up to ₹10 lakh (or its foreign-currency equivalent), regulation 4(2) lets the EDPMS entry be closed on your declaration that the payment has been realised, in full or otherwise — and the declarations can be given to your AD bank quarterly, in bulk. Filing channels for the new form are still settling in, so ask your bank how they want it.
What happened to SOFTEX?
The 2026 regulations do not mention SOFTEX: software is simply a service, declared on the same EDF, with STPI as an alternative to your bank. RBI’s directions of 16 January 2026 supersede the older SOFTEX circulars from 1 October 2026. For invoices before that date, follow what your bank or STPI told you under the old process.
How does it fit with realisation?
The EDF opens the export entry; realising the payment closes it. The full value must arrive within 9 months of the invoice (12 months if it is invoiced or settled in rupees). Both clocks start with the invoice date, so date it correctly. The complete guide to receiving international payments in India puts the whole sequence on one page.
Frequently asked questions
Do freelancers need to file an EDF?
Yes. From 1 October 2026 the requirement covers every exporter of services, including individuals billing foreign clients.
Can one EDF cover several invoices?
Yes. An exporter of services who exported to one or more recipients in a month may submit a single EDF for all of them.
What if I miss the 30-day deadline?
Ask your AD bank to extend it, with your reasons. The regulations let the bank extend the period when it is satisfied the request is reasonable.
Can I file the EDF when the payment arrives instead?
Only for services other than software: those exporters may submit the EDF on or before the date the payment is received. Software exporters file within 30 days of the invoice month-end.
Sources
The primary texts this guide was checked against, on 30 October 2026.
- RBI — Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB dated 13 January 2026 (text as amended up to 22 September 2026)
- RBI — Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(1)/2026-RB dated 22 September 2026
- RBI — A.P. (DIR Series) Circular No. 20, Export and Import of Goods and Services, 16 January 2026
- DGFT — eBRC services on the DGFT portal
General information, not tax or legal advice. These rules changed more than once in 2025–26: confirm the details for your business with your CA or your AD Category-I bank.
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