EDF for service exporters: what Regulation 3(2) requires
An exporter of services must furnish an EDF to the specified authority showing the full export value of services within 30 days from the end of the month in which the invoice is raised. A single EDF can be filed for all services exported to one or more recipients in a month. Exporters of services other than software may submit the EDF on or before the date of receipt of payment. The Authorised Dealer bank may extend the time for filing the EDF on a request citing reasons for delay. For services other than software, the specified authority is the Authorised Dealer in the DTA and the Development Commissioner in an SEZ; for software, it is the Authorised Dealer or STPI in the DTA and the Development Commissioner in an SEZ. The bank must enter EDF details of services in EDPMS within five working days of receiving the EDF.
Time limit for realising export proceeds reduced
| Type of export | Earlier period (as first notified in January 2026) | Period from 1 October 2026 |
|---|---|---|
| Goods (from date of shipment) and services (from date of invoice) | 15 months | 9 months |
| Goods exported to a warehouse outside India (from date of sale) | 15 months | 9 months |
| Exports invoiced or settled in Indian Rupees | 18 months | 12 months |
| Project exports | As per contract | As per contract |
Relief for invoices up to ₹10 lakh
Where a shipping bill or service invoice is up to ₹10 lakh, the EDPMS entry can be closed on the exporter's declaration that payment has been realised, in full or otherwise. The declaration can also be given quarterly for bulk closure. For export value up to ₹10 lakh per invoice, reduction or non-realisation of export value can be allowed on the exporter's declaration. The same ₹10 lakh declaration route applies to import entries in IDPMS.
Other changes to note
Set-off of export receivables against import payables is allowed with the same overseas party or its group or associate companies. Banks may permit third-party receipts and payments where satisfied about the transaction. Merchanting trade: the gap between the outward and inward legs must not exceed six months, extendable by the bank. Transactions undertaken before 1 October 2026 that earlier needed RBI approval are now handled by Authorised Dealers. Banks must publish their internal policy and SOP for export-import transactions and cannot levy penalties on customers for regulatory delays.
What CA firms should tell service exporters
Set up a monthly EDF calendar: invoices raised in October 2026 need an EDF by 30 November 2026. Track receivables against the new 9-month realisation limit for invoices raised from 1 October 2026. Use the ₹10 lakh declaration route to close small EDPMS entries quarterly. Keep EDF and realisation records aligned with export-of-services claims under GST.
What about freelancers?
Frequently Asked Questions
Within 30 days from the end of the month in which the invoice for services is raised. One EDF can cover all services exported in that month. Exporters of services other than software may also file it on or before the date of receipt of payment.
Nine months from the date of invoice for services and from the date of shipment for goods, and 12 months where the export is invoiced or settled in Indian Rupees. The Authorised Dealer can extend it on request.
The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, RBI Notification No. FEMA 23(R)/2026-RB dated 13 January 2026, in force from 1 October 2026.
Yes. For a shipping bill or service invoice up to ₹10 lakh, the EDPMS entry can be closed on the exporter's declaration of realisation, which can also be submitted quarterly for bulk closure.
On 7 October 2026 the RBI stated that individuals are not covered by the reporting requirements and that FAQs will be issued. Business entities exporting services must file.
