Export Declaration Form (EDF) for Services: New FEMA Declaration from 1 October 2026

Summary: From 1 October 2026, every exporter of services must furnish an Export Declaration Form (EDF) declaring the full export value under Regulation 3(2) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. Unlike the earlier regime, where services other than software generally did not require an export declaration, the new framework brings goods, software and other services under a common EDF system and discontinues SOFTEX. For service exports, the EDF must generally be furnished within thirty days from the end of the month in which the invoice is raised, with the first declaration for October 2026 invoices due by 30 November 2026. The declaration feeds into EDPMS and is accompanied by requirements relating to realisation and repatriation, reduction in export value, set-off, third-party receipts and advance receipts. Following the September 2026 amendment, the ordinary realisation period is nine months from the invoice date and twelve months for specified Rupee transactions. Non-compliance may attract FEMA penalties and can also create practical difficulties in crediting foreign remittances and establishing export realisation.

Introduction

Every exporter of services is required, with effect from 1 October 2026, to furnish a declaration in the Export Declaration Form (EDF) stating the full export value of the services. The declaration is to be furnished within thirty days from the end of the month in which the invoice is raised. The requirement arises under Regulation 3(2) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, notified by the Reserve Bank of India as Notification No. FEMA 23(R)/2026-RB dated 13 January 2026.

Until 30 September 2026, a declaration was required for goods (EDF) and for software (SOFTEX), while other services could be exported without any declaration. That exception no longer exists. Consultants, professional firms, IT and IT-enabled service providers, global capability centres and individual freelancers billing overseas clients now fall within a monthly declaration cycle through their Authorised Dealer bank. For invoices raised in October 2026, the first declaration falls due by 30 November 2026.

Legal basis

The declaration is a statutory obligation under Section 7 of the Foreign Exchange Management Act, 1999, and not merely a banking formality. Section 7(1) requires an exporter of goods to furnish a declaration of the full export value, and Section 7(3) requires an exporter of services to furnish a declaration in the form and manner specified. Section 8 obliges a resident to take reasonable steps to realise and repatriate foreign exchange due to him.

For the purposes of the 2026 Regulations, “services” includes software. Software is defined in Regulation 2(1)(e) as any computer programme, database, drawing, design, audio or video signals, or any information in or on any medium other than a physical medium.

Position before and after 1 October 2026

The change lies in coverage and form: one declaration form now applies to goods, software and all other services.

The declaration: who, what, to whom and by when

Who declares.

Regulation 3(2) applies to “an exporter of services” without any exclusion by turnover, constitution or invoice value. A proprietor billing a single overseas client is covered in the same manner as a company.

What is declared.

The EDF, annexed to the Regulations, requires the amount representing the full export value of services. Part 2B of the form captures, for each recipient, the name, address and country, invoice number, date, currency and amount, net realisable value, contract reference, description of services and the Service Accounting Code. The general part requires the IE Code, GSTIN, PAN and the AD code. The exporter also undertakes to deliver the full value to the Authorised Dealer within the period of realisation.

To whom.

The declaration is furnished to the “specified authority” defined in Regulation 2(1)(f).

Where the specified authority is not an Authorised Dealer, Regulation 3(3) requires it to forward the authenticated EDF to the exporter’s Authorised Dealer.

By when.

The time limit is thirty days from the end of the month in which the invoice is raised. Three relaxations are built into Regulation 3(2).

• A single EDF may be furnished for all services exported to one or more recipients in a month.
• An exporter of services other than software may furnish the EDF on or before the date of receipt of payment.
• The Authorised Dealer may extend the period on a request stating the reasons for delay, if satisfied that the request is reasonable.

The period is reckoned from the month of the invoice, not from completion of the service. How the second relaxation operates alongside the thirty-day limit is considered under practical considerations below.

Role of the Authorised Dealer and EDPMS

The declaration feeds the Export Data Processing and Monitoring System (EDPMS), through which each export entry is tracked until realisation. The obligations cast on the Authorised Dealer explain what the exporter will be asked for.

• Under Regulation 18(1)(b), the Authorised Dealer enters the details of an EDF for services in EDPMS within five working days of receiving it from the exporter.
• Under Regulation 4(2), the Authorised Dealer credits the exporter’s account only after satisfying itself of the genuineness of the transaction, and simultaneously closes or updates the EDPMS entry.
• Under Regulation 18(1)(g), the entry is marked off after the export value is realised.
• Under Regulation 19, every Authorised Dealer maintains an internal policy and standard operating procedure listing documents, timelines and charges, and discloses its main features on its website.

For invoices up to Rs. 10 lakh or its equivalent, the first proviso to Regulation 4(2) permits the EDPMS entry to be closed on the exporter’s declaration that payment has been realised in full or otherwise. Such declarations may also be given quarterly for bulk closure of entries. Regulation 19(3) bars the Authorised Dealer from levying any charge or penalty on the exporter for a regulatory delay or violation by the exporter.

Connected obligations that follow the declaration

Once an invoice is declared, it remains an open entry in EDPMS until realised, reduced or set off in the manner the Regulations permit.

The Regulations as originally notified provided fifteen months, and eighteen months for Rupee invoicing. The amendment of 22 September 2026 reduced these periods before the Regulations came into force, and commentary written before that date should be read with this in mind.

Consequences of non-declaration

Failure to furnish the EDF is a contravention of Section 7 of the Act read with Regulation 3. It attracts Section 13(1), under which the penalty may extend to thrice the sum involved where the amount is quantifiable, or to Rs. 2 lakh where it is not, with a further penalty of up to Rs. 5,000 for every day the contravention continues. Compounding under Section 15 is available on application.

The practical consequence arises earlier. An inward remittance for which no EDF exists has no corresponding entry in EDPMS, and the Authorised Dealer is required by Regulation 4(2) to satisfy itself of genuineness and update the entry before giving credit. The absence of a declaration may therefore delay credit of the remittance and the issue of bank realisation evidence. Such evidence supports the claim that payment for an export of services was received in convertible foreign exchange, which is a condition in Section 2(6) of the IGST Act, 2017, and is relied upon in refund claims.

Practical considerations

The following points merit attention in the first cycle of compliance.

• Format and mode of filing. The EDF is prescribed in the Annex to the Regulations, but the mode of submission is governed by each Authorised Dealer’s SOP. The bank’s published procedure should be obtained before the first due date.
• Monthly consolidation. A monthly statement of export invoices, recipient-wise, with SAC, currency and contract reference, drawn from the invoicing system, will meet the requirements of Part 2B.
• Declaration at the time of receipt. Regulation 3(2)(b) allows an exporter of services other than software to furnish the EDF on or before receipt of payment. Whether this operates independently of the thirty-day limit is not free from doubt, and the conservative course is to treat thirty days from the end of the invoice month as the outer limit unless the Authorised Dealer confirms otherwise.
• Advance receipts. Advances received before invoicing should be routed through the Authorised Dealer to whom the EDF will later be furnished, in view of Regulation 10(1).
• Multiple banks. Where remittances are received in accounts with more than one Authorised Dealer, the EDF for an invoice should go to the Authorised Dealer through whom its proceeds will be realised.
• Receipts through online payment platforms. Exporters realising proceeds through payment aggregators should ascertain from the Authorised Dealer concerned how the EDF is to be furnished for such receipts.
• Invoices raised before 1 October 2026. The 2026 Regulations supersede the 2015 Regulations except as respects things done or omitted before supersession. Invoices dated up to 30 September 2026 continue under the earlier framework.
• Reconciliation. Export turnover declared in EDFs should reconcile with zero-rated turnover in GST returns and with export revenue in the books, since the same invoices underlie all three.

Conclusion

The 2026 Regulations bring service exports within the same declare, monitor and realise cycle that has long applied to goods. The declaration itself is a monthly statement of export invoices, but it creates an EDPMS entry against which realisation within nine months will be tracked.

Service exporters should settle the filing procedure with their Authorised Dealer, build the monthly EDF into the invoicing calendar, and ensure that the first declaration for October 2026 invoices is furnished by 30 November 2026.

References

• Foreign Exchange Management Act, 1999: Sections 7, 8, 13 and 15
• Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB dated 13 January 2026: Regulations 2, 3, 4, 5, 6, 7, 8, 10, 13, 18 and 19, and the Annex (Export Declaration Form)
• Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, dated 22 September 2026
• Reserve Bank of India, Directions on Export and Import of Goods and Services, January 2026
• Integrated Goods and Services Tax Act, 2017: Section 2(6)

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Disclaimer: This article is intended for general information and academic discussion only. It is based on the law as it stands on the date of writing, which is subject to change. It does not constitute professional advice or opinion. Readers should refer to the text of the Act, the Regulations and the Directions issued by the Reserve Bank of India, and obtain specific advice, before acting on any matter discussed here. The views expressed are personal to the author.