The RBI introduced new Export Declaration Form rules on October 1, 2026. Service exporters must now file this form within 30 days of the invoice month. Rohan Sewani said, "The EDF is a declaration an exporter gives their bank." This process tracks payments and ensures money reaches India on time.

The RBI released the amended Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, on September 22, which came into effect on October 1, 2026.

According to the regulations, "an exporter of services shall furnish to the specified authority, a declaration in EDF specifying the amount representing the full export value of services, within 30 days from the end of month in which invoice for services has been raised."

The new rules have raised questions about who needs to file the Export Declaration Form (EDF), how the process works, and what charges banks can levy. Here's what experts have to say.

What is the Export Declaration Form (EDF)?

Rohan Sewani, Head of Operations & Customer Experience at Skydo, said the Export Declaration Form (EDF) is a declaration an exporter gives their bank. It lists the exports made and the money they expect to receive for them.

The bank uploads it to RBI's Export Data Processing and Monitoring System (EDPMS). The entry stays open against the exporter's PAN until the payment comes in and the bank matches it.

Until now, export reporting under EDPMS was largely relevant to goods exports and certain software exports. From October 1, the requirement has expanded to a wider range of service exporters, including those providing software, consulting, marketing, design and other services to overseas clients, he added.

What is the deadline to file the EDF form?

Sewani said the EDF must be submitted within 30 days from the end of the invoice month. The first submission deadline is 30 November 2026 for invoices raised during October.

Exporters can consolidate their monthly invoices into one EDF to simplify the process, although filing separate declarations for different invoices is also permitted.

Another important change is the time allowed to bring export proceeds into India. It has been shortened from 15 months to nine months, and from 18 months to 12 months for exports invoiced or settled in Indian rupees, effective 1 October. This realisation deadline is separate from the EDF filing deadline, he explained.

What is the step-by-step process for filing an EDF?

Sewani explained that service exporters required to file an EDF should follow these steps:

Start by organising the export invoices raised during the month. Each invoice should contain the overseas client's details, invoice number, date, currency, amount, and description of services.

Identify the correct Services Accounting Code (SAC) for their services and the AD code of the bank branch where they hold their account. The form also requires the exporter's IEC, GSTIN and PAN, contract reference and net realisable value for each invoice.

The next step is to prepare the declaration using these details. Service exporters need to complete Part 1, covering general information, and Part 2B, covering the export value of services. They also need to identify the type of payment, including whether it is an advance or non-advance payment.

The filing deadline is 30 days from the end of the invoice month. For invoices raised in October 2026, the deadline is 30 November 2026. Exporters can also submit their declarations earlier.

The authorised dealer bank then records the declaration in RBI's Export Data Processing and Monitoring System (EDPMS). When the corresponding payment is received, the inward remittance information is matched with the export declaration, allowing the bank to reconcile and close the entry.

For invoices up to ₹10 lakh, the entry can be closed on the exporter's own declaration that the payment has been received.

Is EDF filing mandatory for freelancers and YouTubers?

Sewani said the new EDF requirement covers a much wider range of service exporters. Large IT companies that previously filed SOFTEX forms have now moved to the EDF framework.

However, the RBI Governor's clarification on October 7 indicated that individuals undertaking transactions of a personal nature would be exempt. Clarity on whether all freelancers qualify for this exemption is still awaited through the RBI's FAQs.

Covered: Companies, LLPs, partnership firms, agencies, IT and SaaS businesses, and global capability centres billing overseas clients.

Likely exempt: Individuals earning in a personal capacity. This includes freelancers, tutors, and YouTubers or creators receiving Google AdSense payouts in their own name, subject to RBI's FAQs.

Grey area: sole proprietors with GST, Udyam/MSME, or other business registrations.

"In practice, banks are currently applying this differently. Some have stopped asking individuals for an EDF, while others are still asking for it regardless of whether the exporter is a registered business," he added.

What fees can banks levy and what do RBI rules say?

Sewani said the RBI has not prescribed a fixed fee or cap for EDF filing. Under the 2026 export regulations, banks can charge for handling export transactions, but the charges must be reasonable and proportionate to the service provided.

Since some banks are charging per EDF, consolidating a month's invoices into one declaration may help exporters keep costs down. If a charge appears excessive, exporters can raise the issue through the bank's grievance redressal process and, if unresolved, approach the RBI Ombudsman, he added.