EDF for services: the 2026 rules explained

If you bill clients outside India for services, your bank is about to ask you for a new form every month. It's called the EDF for services, it started on 1 October 2026, and the first one is due on 30 November. If this is the first you've heard of it, you're not late. RBI hasn't even published its FAQs yet.

Here's what it is and what to do before the end of November.

What is the EDF for services?

EDF stands for Export Declaration Form. Exporters of goods have filed one for years. Services never had to. Now they do.

The rules are the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, notified as FEMA 23(R)/2026-RB. RBI published them in January 2026, they came into force on 1 October 2026, and an amendment on 22 September 2026 shortened the time you get to collect your money. More on that below.

The form itself is simple. You tell your bank which clients abroad you billed this month, for how much, in which currency. Your bank (the Authorised Dealer, or AD bank: the one your foreign payments land in) records each invoice in RBI's export tracking system, EDPMS. When the money arrives, the bank matches it to that record and closes it.

Software exporters will recognise this, because the EDF replaces SOFTEX. For design studios, consultancies, marketing and support firms, it's new. They had nothing like it before.

Who has to file

Companies, LLPs and partnership firms that export services, registered or not. That part is clear.

Individuals are murkier. On 7 October 2026, RBI said individuals are not covered for contracts of a personal nature, and promised FAQs. If you do occasional work in your own name, you most likely don't need to file. Proprietors and full-time freelancers are less clear until the FAQs arrive, so ask your bank. Either way, keep your invoices and FIRCs in order. More in Do freelancers need to file an EDF?

There's no minimum, either. A firm billing one client ₹80,000 a month is an exporter of services in exactly the same way as one billing crores.

The two clocks: 30 days and 9 months

They're easy to mix up, and they measure different things.

The first clock is filing. Your EDF is due within 30 days after the end of the month you raised the invoice in. One EDF can cover every invoice from that month, however many clients.

The second clock is getting paid. The full value of each invoice has to be received in India within 9 months of the invoice date, or 12 months if you invoice or settle in rupees. Your bank can extend it if you ask with reasons. The January text had allowed 15 months; the September amendment pulled it back to 9.

The 30-day clock is the one I'd worry about. It runs every month, forever. October's invoices are due by 30 November, November's by 30 December, and a busy month is exactly when it slips.

The ₹10 lakh rule is not an exemption

You'll see "₹10 lakh" quoted everywhere, and it's easy to read it as "small invoices don't count". They do. Every invoice still goes on the EDF.

The limit only changes what happens after you're paid. For invoices up to ₹10 lakh, your bank can close the record on your own declaration that the money came in, and you can give that declaration once a quarter for the lot. Same if a client paid a bit less than the invoice because of bank charges or a discount: for small invoices your word can be enough. Above ₹10 lakh, the bank has to be satisfied with your reasons.

Each bank wants it differently

RBI's regulations describe what the EDF must say. They don't fix how you hand it to your bank, so each bank is deciding for itself. When I checked on 9 October:

• HDFC Bank has published its own Excel workbook for services, one row per client and currency, with the invoices listed under each.
• ICICI Bank uses the RBI form with its own AD code printed on it.
• SBI asks for a request letter "in the bank's standard format", but doesn't publish that format.
• Axis, Kotak, IDFC FIRST, Yes, IndusInd and the rest haven't published anything yet.

So the answer depends on where you bank. With HDFC, you need HDFC's workbook. Anywhere else, the RBI form plus a covering letter that lists your invoices and carries the standard declarations is the safest thing to walk in with.

That gap is why I built Ratify EDF. It fills your bank's own format where one exists, groups the invoices the way that bank asks, and adds the letter where it doesn't. If your bank only wants the bare RBI form, though, there are free tools that fill just that, and honestly they'll do the job.

Before 30 November

1. Ask your bank how it wants the EDF: its own format, the RBI form, or a letter. Email beats a branch visit, because you get the answer in writing.
2. List October's export invoices with client, country, invoice number, date, currency and amount. If your numbering is a mess, fix it now; it only gets harder.
3. Note the 9-month date for each invoice, so you know which payments to chase first.
4. File by 30 November. Then put a monthly reminder in your calendar for the 30-day clock.

If you'd rather not type the pack out by hand, Ratify EDF makes it in your browser, free, and nothing you type leaves your computer. No proper export invoices yet? The invoice maker creates them and adds them to the month's EDF in one click.

Still waiting on RBI

RBI has said FAQs are coming. I expect them to settle who counts as an exporter (sole proprietors and creators, mainly) and maybe tidy up how filing works in practice. I'll update this page when they're out. The notification itself is on RBI's site.

Researched 9 October 2026, from RBI's FEMA 23(R)/2026 regulations as amended on 22 September 2026, RBI's statement of 7 October 2026 and published bank guidance.