EDF checklist for chartered accountants: service-export clients from October 2026

From October 2026 your service-export clients have a monthly RBI filing alongside GST. Here is a working checklist: which clients file, what to collect, the calendar, how the EDF reconciles with GSTR-1, and the mistakes we see most.

Last updated 11 Oct 2026 · Not legal or tax advice

Checked against the regulations and the sources listed at the end.

Which clients file

Companies, LLPs and partnership firms that export services: yes, monthly, from invoices dated October 2026 (FEMA 23(R)/2026-RB, Regulation 3(2)). No minimum amount.
Individuals (freelancers, consultants, creators): on 7 October 2026 RBI said individuals needn't report transactions of a personal nature; its FAQ is awaited. Until then, ask the client's bank.
Sole proprietors trading under a business name: unclear whether RBI's remark covers them. Ask the bank.
Invoices dated before 1 October 2026: the earlier rules apply; follow the AD bank's instruction for those paid after 1 October.

The monthly and yearly calendar

EDF: within 30 days after the end of each invoice month, one per AD bank (October invoices by 30 November 2026, November by 30 December, December by 30 January 2027).
GSTR-1: 11th of the next month, or 13th after the quarter under QRMP; exports go in Table 6A, never in the IFF. GSTR-3B: 20th, or 22nd/24th after the quarter.
Quarterly, if the bank wants it: one declaration closing EDPMS entries for invoices up to ₹10 lakh.
Per invoice: payment within 9 months (12 if invoiced or settled in rupees), and, under an LUT, IGST with interest if payment hasn't arrived by the later of one year or the FEMA period (CGST Rule 96A).
Yearly: the LUT (Form RFD-11) before the first export of each financial year; the IEC annual update between April and June if the client holds one.

What to collect from each client every month

Export invoices with the SAC code per line (the EDF has a SAC column per invoice), the client's country, currency and contract or SOW reference.
The FIRA, e-FIRC or bank advice for each payment received, and the purpose code the bank recorded.
Third-party payer details (platform, parent company, employer of record) and the agreement naming them.
The bank's format: most take the RBI form; HDFC has its own request letter; SBI wants its own request letter with FEMA declarations. Many banks ask for an IEC.

Reconciling the EDF with GST and payments

Invoices: every export invoice of the month should appear both in the EDF's Part 2B and in GSTR-1 Table 6A (with or without payment of tax). A mismatch usually means a missed invoice or a wrong month.
Rupee values differ, legitimately: GST uses the rate for the time of supply under CGST Rule 34(2); the EDF rate isn't prescribed, so follow the bank's convention. Keep the source of each rate.
Payments: match each FIRA to its invoices. Fees deducted by platforms or banks make the credit short: record the difference and the reason; up to ₹10 lakh per invoice the bank can accept the lower amount on the client's declaration (Regulation 6).
Watch the 9-month date per invoice and ask the bank for an extension before it passes.

Certificates banks may ask you for

None for the EDF itself: the exporter signs the declaration.
Banks may ask for a CA certificate for a set-off of receivables against payables (Regulation 7; Axis Annexure 3A) or for a write-off above ₹10 lakh (Axis Annexure 2A). Check the client's bank's published policy: each AD bank must publish its policy and the main features of its SOP (Regulation 19).
The DGFT e-BRC is a separate process from the EDF and from closing entries in EDPMS.

Common errors

Export receipts coded as personal remittances (for example P1301 family maintenance) or received in a personal Wise account: weak evidence of an export. Fix the purpose with the bank and the provider.
NIL GST returns filed for periods with export invoices: not allowed; exports are zero-rated supplies.
No LUT for the current financial year on invoices endorsed "under LUT".
Invoices missing the SAC, the client's address or the place of supply.
Services to the client's own branch abroad treated as exports. (Agent and intermediary services, on the other hand, can be exports from 30 March 2026, when IGST section 13(8)(b) was omitted.)

Do it in easylancing

Prepare the month's EDF free with the EDF generator (in your bank's format: EDF form by bank), or create a free account: it builds each month's EDF from your invoices, tracks the 9-month payment deadline and prepares the GST export figures.

Questions

Which of my clients must file the EDF?

Companies, LLPs and firms that export services file monthly from October 2026 invoices. For individuals, RBI said on 7 October 2026 that personal-nature transactions needn't be reported, and its FAQ is awaited: ask the client's bank. Sole proprietors are unclear.

Does the EDF have to match GSTR-1?

Every export invoice of the month should appear in both the EDF's Part 2B and GSTR-1 Table 6A. The rupee values can differ, because GST uses the Rule 34(2) rate and the EDF follows the bank's convention.

Can a CA file the EDF for a client?

The regulations make the exporter responsible; the exporter signs the declaration. You can prepare the form and documents. Banks accept it through their own channels, usually the client's branch, relationship manager or trade portal.

Do I need to certify the EDF as a CA?

No. The exporter signs the EDF declaration. Banks may ask for a CA certificate for other things, such as a set-off of receivables against payables or a write-off above ₹10 lakh (Axis publishes formats for both).

What happens if a client files late?

The bank can extend the period on a request with reasons (Regulation 3(2)(c)). Regulation 19(3) bars the bank from penalising the client for a regulatory delay; penalties under FEMA section 13 come only through adjudication.