EDF and export compliance for Indian service-export companies (2026)

Does this apply to your company?

Yes, if you invoice clients outside India for services delivered from India: software and IT services, SaaS, design and creative agencies, consulting, KPO and BPO. The regulations (RBI notification FEMA 23(R)/2026-RB, in force 1 October 2026) have no minimum amount and no exemption for small exporters.

On 7 October 2026 RBI said individuals need not report transactions of a personal nature. That was about individuals; companies, LLPs and partnership firms file.

The monthly EDF

• One EDF per month per AD bank, listing every export invoice of that month in Part 2B, due within 30 days after the month ends (Regulation 3(2)). October 2026 invoices are due by 30 November 2026.
• File with your AD bank, normally the one where the export proceeds are received. Software exporters may also file with STPI (Regulation 2(1)(f)).
• Services other than software may file on or before the date payment is received instead (Regulation 3(2)(b)). Late? Ask your bank: it can extend the period on a request with reasons (Regulation 3(2)(c)).
• The bank enters the EDF in EDPMS within 5 working days and marks it off as payments arrive (Regulation 18(1)(b)).
• Every invoice row needs a SAC code: the EDF form has a SAC column for each invoice.
• Some banks want an invoice-wise annexure or a "gist of invoices" with a consolidated EDF (IndusInd, RBL), and Axis and RBL mention a file-upload option in EDPMS for invoice-wise details. Standard Chartered has an EDF upload template.

Bank formats and documents

Most banks take the RBI form as it is (Axis calls it Annexure 6). HDFC Bank has its own request-letter format. Banks commonly ask for a request letter with FEMA declarations, the signed EDF, invoices, the contract, SOW or purchase order, and proof of service; many also want an IEC. See the EDF form for each bank.

Software exporters: bank or STPI

For software exported from a domestic tariff area, the "specified authority" that takes the EDF is an AD bank or STPI (Regulation 2(1)(f)); for other services it is the AD bank. SOFTEX certification by STPI is gone. As of 11 October 2026 STPI hasn't published a notice or fees for certifying EDFs, so most companies file with their AD bank.

Getting paid: 9 months, extensions and write-offs

• Realise and repatriate the full export value within 9 months of the invoice date, or 12 months if invoiced or settled in rupees (Regulation 5(1), as amended on 22 September 2026). Your bank can extend it on request.
• Invoices up to ₹10 lakh: your bank can close the EDPMS entry, or accept a lower amount, on your own declaration, per invoice or in bulk each quarter (Regulations 4(2) and 6). Above ₹10 lakh, a reduction or write-off is at the bank's discretion under its published policy; Axis, for example, asks for a CA certificate (its Annexure 2A).
• A payment still outstanding more than a year after its deadline means further exports must be against full advance or an irrevocable letter of credit (Regulation 13). The regulation sets no end date for this.
• Your bank may not penalise you for a regulatory delay (Regulation 19(3)). Penalties under section 13 of FEMA come only through adjudication.

Set-off, advances and EEFC

• Set-off: your bank may let you set export receivables off against import payables with the same overseas party or its group companies, within the realisation period (Regulation 7). Banks may ask for a CA certificate (Axis: Annexure 3A).
• Advances: an advance and the later export must go through the same AD bank unless you tell both banks (Regulation 10). The regulations set no fixed period for rendering the services after an advance.
• EEFC: you can credit up to all of your export earnings to an Exchange Earners' Foreign Currency account, but each month's accruals not used for approved purposes must be converted to rupees by the end of the next month (RBI Master Direction on deposits and accounts).

Third-party payers, platforms and payment aggregators

• If someone other than the client pays (a parent company, a platform, an employer of record), show them on the EDF as the third party with the relationship. The bank may accept it if satisfied the transaction is genuine (Regulation 8), commonly against a tripartite agreement or an invoice or contract naming them.
• Card, marketplace and payment-aggregator receipts get no special treatment in the regulations: the invoices still go on the EDF. For high volumes, the ₹10 lakh declaration (quarterly in bulk) is the practical way to close entries.
• Payment aggregators (Stripe, Razorpay, Skydo, Wise Business, PayPal) don't file the EDF. Which AD bank should receive it for aggregator receipts isn't settled; the common practice is your own bank, where the rupees land. Razorpay says ICICI-settled merchants need an EDF number before capture.

GST alongside the EDF

• File a Letter of Undertaking (Form GST RFD-11) each financial year to export without paying IGST.
• Under an LUT, unpaid exports become taxable: if payment hasn't arrived within the later of one year from the invoice or the FEMA period (with any extension), pay the IGST with interest within 15 days (CGST Rule 96A).
• Report exports in GSTR-1 Table 6A and GSTR-3B Table 3.1(b). A period with export invoices can't be filed as NIL.
• Services to your own branch or office abroad are not exports (supplier and recipient must not be establishments of the same person). The intermediary rule that kept agents and brokers out of exports (IGST section 13(8)(b)) was omitted by the Finance Act 2026 from 30 March 2026.

Invoices before 1 October 2026

SOFTEX was abolished on 1 October 2026. Invoices dated before then fall under the earlier rules; RBI hasn't said whether one paid after 1 October needs an EDF. Commentators generally say no, but follow your AD bank's instruction.