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Export Declaration Form (EDF) for services: the 2026 guide for freelancers

From 1 October 2026, Indian exporters of services declare each month's export invoices to their bank in an Export Declaration Form (EDF), within 30 days after the month ends. On 7 October RBI said individuals may not need to. Here is what it is, who files, when, where, and how.

Last updated 09 Oct 2026 · Not legal or tax advice

Make your EDF now with the free generator: enter the month's invoices and print the form in the RBI layout.

What is the Export Declaration Form?

The Export Declaration Form (EDF) is a declaration of the full export value of what you exported, filed with a "specified authority", which for most freelancers is their bank. It comes from the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, RBI notification FEMA 23(R)/2026-RB, Reg. 3(2), in force from 1 October 2026.

One form covers goods and services. Under the earlier rules, software exporters filed SOFTEX forms and other service exporters filed nothing. SOFTEX has now been abolished and folded into the EDF, so all service exporters who file use the same form.

Who must file an EDF?

The regulations say every exporter of services, with no minimum amount and no exemption for individuals or small exporters (FEMA 23(R)/2026-RB, Reg. 3(2)).

RBI on individuals, 7 October 2026

RBI Deputy Governor Rohit Jain said "the individuals are not included with respect to the reporting requirements for the contracts of a personal nature". Governor Sanjay Malhotra said individuals don't have to report transactions of a personal nature, whatever the amount, and gave tutoring and small software work for clients abroad as examples. RBI has promised an FAQ; it isn't out yet, and the regulations haven't changed. Sources: RBI Governor and Deputy Governor, 7 Oct 2026, as reported by Business Today; RBI Governor, 7 Oct 2026, as reported by Moneycontrol.

Until the FAQ says who counts as an individual:

  • Company, LLP or partnership firm: File the EDF. RBI's remarks were about individuals.
  • Individual, invoicing in your own name: RBI's remarks suggest you don't need to file, but where "personal nature" ends isn't defined. Ask your bank whether it wants an EDF from you, and keep your invoices and payment proofs either way.
  • Sole proprietorship under a trade name: Unclear: a proprietorship is legally you, but RBI hasn't said whether its remarks cover a proprietary business. Ask your bank.

Guides by audience: service-export companies, YouTubers and creators, and chartered accountants.

Either way, keep your invoices and payment proofs, and get paid within the realisation period.

"Software" is defined broadly: any computer programme, database, drawing, design, audio or video signals, or other information delivered other than on a physical medium. Most digital work counts.

The exporter files. Payment providers and platforms such as Wise, Skydo, Payoneer, PayPal, Deel or Upwork don't file the EDF for you.

When is the EDF due?

Within 30 days from the end of the month in which you raised the invoice (Regulation 3(2)). One EDF can cover all of a month's invoices, even for several clients.

Invoices dated in EDF due by
October 2026 30 Nov 2026
November 2026 30 Dec 2026
December 2026 30 Jan 2027
January 2027 02 Mar 2027
February 2027 30 Mar 2027
March 2027 30 Apr 2027

Exporters of services other than software may also file on or before the day the payment arrives. Some banks' published policies ask for it sooner: Standard Chartered by the date the money arrives, Bank of America by then for services other than software, and HSBC within 10 working days of a credit. Use the due date calculator for any invoice date.

Where do you file it?

With the "specified authority" (Regulation 2(1)(f)). For services exported from India that is an Authorised Dealer bank (in practice an AD Category-I bank). Software exporters may also file with STPI. The regulations don't say which AD bank. In practice it usually goes to the bank where your export money is received; for payment-aggregator routes, confirm with your bank or provider. Payments banks are not AD Category-I banks and can't take an EDF.

Most banks take the RBI form as it is; HDFC Bank has its own request-letter format. See the EDF form by bank: HDFC, ICICI, Axis, SBI, Kotak, PNB, Canara and Bank of Baroda.

RBI has not prescribed a channel. Each bank publishes its own policy. Most take the EDF at the branch or through your relationship manager; some business customers can use a trade portal. See which banks take the EDF and how, or go straight to HDFC Bank, ICICI Bank, SBI, Axis Bank or Kotak.

What goes in the form?

The form has five parts. As a service exporter you fill three:

  • Part 1, general information: type of export (Service), your PAN, IEC and GSTIN, name and address, your bank's AD code and branch, the client (or "As per Part 2B" for several), and any third party who pays you.
  • Part 2B, export value of services: one row per invoice: client name and address, country, invoice number, date, currency and amount, net realisable value, contract reference, description and SAC code.
  • Part 4, declaration: you declare the details are true and undertake to bring in the full value by a date within the RBI period. Sign and date it.

Parts 2A (goods) and 3 don't apply to services; Part 5 is for the bank. See every field explained.

How to file the EDF, step by step

  1. Issue export invoices. Invoice in the currency agreed with your client: usually their currency; rupee invoicing is possible only within RBI's framework. Show the client's name, address and country, and the SAC code (asked for in the EDF, and by CGST Rule 46 on a GST tax invoice). If you are GST-registered and export under an LUT, add the export endorsement.
  2. Confirm which AD bank takes your EDF. The EDF goes to an Authorised Dealer bank (in practice an AD Category-I bank), the 'specified authority'. In practice that's usually the bank where your export money is received; for payment-aggregator routes, confirm with your bank or provider. Payments banks can't take an EDF.
  3. After the month ends, list that month's invoices. Every export invoice dated in the month, for that bank, becomes a row in Part 2B: client, country, invoice number, date, currency, amount, description and SAC code.
  4. Fill Part 1. Your PAN, IEC (if you have one), GSTIN (if registered), name and address, the bank's AD code and branch address, the type of export (Service) and, if a platform pays you, the third-party payer and its relationship to you.
  5. Sign the declaration (Part 4). You declare the particulars are true and undertake to realise the money within the RBI period. Sign and date it.
  6. Submit it to your bank within 30 days after the month ends. Use the channel your bank asks for, with the documents it wants. Record the date and any reference number the bank gives you.
  7. Track payment for 9 months. Match each payment's FIRA or bank advice to its invoice. If money will be late or short, ask your bank for an extension or a reduction before the deadline.

Which documents does the bank want?

Each bank decides (Regulation 19). Commonly asked for:

  • the signed EDF and a covering letter;
  • copies of the invoices, showing the SAC code;
  • the contract, statement of work or purchase order;
  • the FIRA, e-FIRC or bank advice for payments already received.

Some banks also ask for an IEC. It isn't legally required for services, but it costs ₹500 on the DGFT portal and its number is your PAN, so getting one before your first EDF is the safe choice.

How long do you have to get paid?

The full export value must be realised and repatriated within 9 months of the invoice date, or 12 months if you invoice in rupees (Regulation 5(1), as amended by FEMA 23(R)/2026-RB, Reg. 5(1) as amended by FEMA 23(R)/(1)/2026-RB). Articles that say 15 months predate that amendment.

If a payment will be late, ask your bank for an extension before the deadline. If you received less than invoiced (bank charges, platform fees), ask your bank to accept the reduction. For invoices up to ₹10 lakh the bank can do this, and close the export entry, on your own declaration, per invoice or in bulk once a quarter.

Paid through Upwork, Deel, Wise, PayPal or Payoneer?

The route doesn't change whether you file, and the platform doesn't file for you. Common practice is to file it with the AD bank where the rupees land, but for payment-aggregator receipts that isn't settled, so confirm with your bank. Keep the provider's FIRA or advice, and name the platform as the third-party payer when it pays you instead of your client. Platform-by-platform guide.

What if you file late or don't get paid?

Your bank may not penalise you for a regulatory delay (Regulation 19(3)). FEMA penalties are imposed only through adjudication. If an invoice stays unpaid for more than a year after its deadline, your future exports must be against full advance payment or a letter of credit until it is settled or written off (Regulation 13).

Frequently asked questions

What is the Export Declaration Form (EDF) for services?

The EDF is a declaration of the full export value of your services, filed with your bank. It comes from the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (RBI notification FEMA 23(R)/2026-RB), in force from 1 October 2026. One form covers goods and services. For software it replaces the old SOFTEX form; for other services it is new.

Do freelancers have to file an EDF?

Possibly not, if you work as an individual. The 2026 regulations themselves have no minimum amount and no exemption for individuals or small exporters. But on 7 October 2026 RBI's Governor said individuals don't have to report transactions of a personal nature, whatever the amount, and gave tutoring and small software work for clients abroad as examples. RBI has promised an FAQ. Until it's out: companies, LLPs and partnership firms file; if you invoice in your own name or as a sole proprietor, ask your bank whether it wants an EDF from you.

When is the EDF due?

Within 30 days from the end of the month in which you raised the invoice (Regulation 3(2)). Invoices dated October 2026 are due by 30 November 2026; November invoices by 30 December 2026; December invoices by 30 January 2027.

Where do I file the EDF?

With the 'specified authority' defined in Regulation 2(1)(f): for services exported from India that is an Authorised Dealer (in practice an AD Category-I bank), and software exporters may also use STPI. The regulations don't say which AD bank. The common practice is the AD bank where the export proceeds are received; if your money comes through a payment aggregator or platform, confirm with your bank or provider which AD bank will handle your EDF. RBI has not prescribed a channel: most banks take it at the branch or through your relationship manager, and some business customers can use a trade portal. Ask your bank how it wants it.

Can one EDF cover all my invoices for the month?

Yes. Regulation 3(2)(a) lets an exporter who served one or more clients in a month file one EDF for all of that month's exports. List each invoice as a row in Part 2B of the form.

I'm paid through Wise, Payoneer, PayPal, Deel or Upwork. Do I still file?

If you have to file, yes: the route doesn't change it (individuals: see RBI's 7 October remarks above). Payment providers and platforms don't file the EDF for you. Which AD bank should receive the EDF for payment-aggregator receipts is not settled. The common practice is the AD bank where the rupees land, but confirm with your bank or provider. Keep the provider's FIRA or payment advice, and put the platform in the third-party payer fields when it, not your client, pays you.

How long do I have to receive the payment?

The full export value must be realised and repatriated within 9 months of the invoice date, or 12 months if the export is invoiced or settled in Indian rupees (Regulation 5(1), as amended on 22 September 2026). Whether a platform's local rupee payout counts as 'settled in rupees' isn't settled, so easylancing uses 9 months unless the invoice itself is in rupees. Older articles quoting 15 months are out of date. Your bank can extend the period on request.

If I don't need to file the EDF, does the 9-month payment deadline still apply?

Assume it does. RBI's 7 October remarks were about reporting. Separately, FEMA (section 8) requires a person resident in India to realise and repatriate foreign exchange due to them, and RBI hasn't said individuals are outside the realisation period. easylancing keeps tracking it until the FAQ says otherwise.

Which exchange rate do I use, if I only know the rate when the money arrives?

Your invoice doesn't need an exchange rate. If you are GST-registered, CGST Rule 34(2) asks for the rate determined under generally accepted accounting principles for the time of supply: usually the invoice date, or the payment date if you were paid before invoicing. The RBI/FBIL reference rate or your bank's TT rate, applied consistently, are common choices; the rate you later get when the money arrives is a different figure. The EDF regulations don't prescribe a rate for the form's INR total: follow your bank's convention if it has one, otherwise use the rate you used for GST, and keep its source.

What about fees taken by Wise, Deel, Upwork, PayPal or my bank?

Invoice and declare the full amount you billed. If a platform, transfer service or bank deducts a fee, less arrives than invoiced. Record the difference and the reason. If the fee is known when you prepare the EDF, show the amount after it as the 'net realisable value'. For invoices up to ₹10 lakh your bank can accept the lower amount on your own declaration (Regulation 6); above that it needs the bank's approval. If you are GST-registered, a fee charged by a platform outside India may attract GST under reverse charge, so ask your CA.

What documents does the bank need with the EDF?

Each bank sets its own list (Regulation 19). Commonly asked for: the signed EDF, copies of the invoices with the SAC code, the contract, SOW or purchase order, the FIRA or bank advice for payments already received, and a covering letter.

Do I need an IEC (Import Export Code) for the EDF?

The law doesn't require an IEC for exporting services, but the form has an IEC field and several banks ask for one. An IEC costs ₹500 on the DGFT portal and its number is your PAN, so getting one before your first EDF is the safe choice.

What about invoices dated before 1 October 2026?

They are governed by the earlier export rules. Regulation 20 lets AD banks handle pre-October matters that used to need RBI approval, but it doesn't say whether these invoices need an EDF, and RBI has not said whether a pre-October invoice paid after 1 October needs an EDF. Commentators generally say it doesn't, but confirm with your AD bank and follow its instruction.

What is the ₹10 lakh rule?

For invoices of up to ₹10 lakh, your bank may close the export entry, or accept a lower amount, on your own declaration instead of payment evidence. You can make that declaration per invoice or in bulk once a quarter. It does not by itself remove the need to file the EDF.

What happens if I file late or the money never arrives?

Your bank may not penalise you for a regulatory delay (Regulation 19(3)). Penalties under section 13 of FEMA are imposed only through adjudication. If an export stays unpaid for more than a year after its deadline, your future exports must be against full advance payment or an irrevocable letter of credit (Regulation 13). The regulation sets no end date for this; ask your bank.

Is the EDF the same as SOFTEX?

SOFTEX was abolished from 1 October 2026 and folded into the EDF. Software exporters now file the EDF like other service exporters, subject to RBI's 7 October remarks about individuals.

Can I file a NIL GST return in a month with export invoices?

No. If you are GST-registered, an export invoice is a zero-rated supply, and a month or quarter with any outward supply is not NIL. Report exports in GSTR-1 (Table 6A) and GSTR-3B (Table 3.1(b)). A NIL return is only for periods with no supplies, no reverse-charge liability and no input tax credit.

Sources

This guide summarises the regulations in plain language. It is not legal, tax or foreign-exchange advice. Your bank's policy decides the format, channel and documents. Check with your bank or a chartered accountant before you file.