Service Exports: EDF Deemed Filed for Individuals and Receipts Up to ₹10 Lakh
From 1 October 2026, a resident individual who exports services is treated as having filed the Export Declaration Form (EDF) once the bank has the payment details it needs to credit the export receipt, and companies, LLPs and firms get the same treatment for inward remittances of up to ₹10 lakh. The relief comes from the Foreign Exchange Management (Export and Import of Goods and Services) (Second Amendment) Regulations, 2026, notified by the RBI on 2 November 2026 and in force from 1 October 2026, the same day the new export-import regulations took effect. The amendment also narrows the import-side reporting in IDPMS for services.
If you invoice foreign clients for consulting, software, design, professional or other services, here is what changed and what you still need to file.
What changed
- The basic rule stays: under regulation 3(2) of the FEMA (Export and Import of Goods and Services) Regulations, 2026, an exporter of services must give the specified authority an EDF showing the full export value within 30 days from the end of the month in which the invoice was raised.
- Resident individuals: a new proviso (a) treats the EDF as submitted when the individual gives the Authorised Dealer (AD) bank the information required in relation to the receipt of payment, for crediting the exporter’s account. There is no value limit for individuals.
- Everyone else (companies, LLPs, firms and other non-individuals): a new proviso (b) gives the same deemed filing, but only where the value of the inward remittance for the service is not more than ₹10 lakh (or its equivalent in foreign currency).
- New definition: “resident individual” now means a person resident in India who is a natural person.
- Import of services: the AD bank now enters an import of services in IDPMS only where the importer is not a resident individual and the invoice or contract value is more than ₹10 lakh, within five working days of receiving the details. Earlier, the bank had to enter import-of-service details as declared and submitted by the importer, with no value threshold, within five working days of receipt of documents.
Who it affects
Freelancers, consultants, doctors, designers, developers and other professionals who are resident in India and receive fees from abroad in their own name are the biggest gainers: they no longer need a separate EDF for each month’s invoices. Companies, LLPs and firms exporting IT, software, back-office or professional services benefit only for smaller receipts. Because software is included in “services” under the regulations, software exporters are covered by the same rules. Businesses that pay foreign vendors for services see lighter IDPMS reporting on smaller invoices.
How it works and the key dates
| Exporter | Inward remittance | EDF position |
|---|---|---|
| Resident individual | Any amount | Deemed filed once payment details are given to the AD bank for credit |
| Company, LLP, firm or other non-individual | Up to ₹10 lakh | Deemed filed once payment details are given to the AD bank for credit |
| Company, LLP, firm or other non-individual | Above ₹10 lakh | Regular EDF within 30 days from the end of the invoice month |
Where a regular EDF is still needed, invoices raised in October 2026 need an EDF by 30 November 2026, November invoices by 30 December 2026 and December invoices by 30 January 2027. The existing provisos continue, now renumbered (c) to (e): one EDF can cover all of a month’s exports to one or more recipients, exporters of services other than software may file on or before the date payment is received, and the AD bank can extend the time on a reasoned request.
What it does not change
- Export of goods: the EDF rules for goods, including deemed submission through the shipping bill at EDI ports, are untouched.
- The time limits for realising and repatriating export proceeds are not part of this amendment.
- Deemed filing depends on the bank having the payment information it needs, so incomplete or wrong remittance details can still leave an export unreported.
What to do now
- Individuals: respond promptly when your bank asks for details of an inward remittance, and keep the invoice and agreement for each receipt on file.
- Companies, LLPs and firms: list your service invoices from October 2026 onwards, mark every remittance above ₹10 lakh, and file the EDF for those by the dates above.
- Check October 2026 entries with your AD bank. The amendment was notified on 2 November 2026 but applies from 1 October 2026, so confirm how the bank is treating receipts already credited and that EDPMS shows no open entries.
- Importers of services: if you are not an individual and the invoice or contract value is above ₹10 lakh, give your AD bank the import details promptly so it can report them in IDPMS.
Need help with export reporting under FEMA?
TAXAJ handles FEMA compliance for exporters, importers and foreign-owned businesses from offices in Delhi, Bengaluru, Goa and Bihar. For another recent RBI change, see our note on FEMA compounding moving to Regional Offices. For every other RBI change, see our FEMA and RBI updates page.
Source: RBI Notification No. FEMA 23(R)/(2)/2026-RB dated 2 November 2026, read with the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB dated 13 January 2026). Last updated 4 November 2026. This is general information, not advice on any particular case.
