New FEMA Export Rules from 1 October 2026: Monthly EDF for Service Exporters, SOFTEX Ends, and Export Money Must Arrive in 9 Months

EDF under FEMA from 1 October 2026: service exporters declare invoices to their bank within 30 days of month-end, and money must arrive in 9 months.

Update, 10 October 2026: On 7 October, RBI said individuals are not covered by the reporting requirement for contracts of a personal nature, and that it will issue FAQs shortly. News reports quote the Governor giving online tutoring and small software work as examples. The FAQs had not been issued by 10 October 2026, and the written rules have not changed. We will update this page when they come.

Take a Rajkot software developer who bills two clients in Canada every month. He has never filed a SOFTEX form, his money comes in through a payment platform, and so far his bank has never asked him for anything beyond a purpose code. From October, his bank may ask him for an EDF. But on 7 October RBI said individuals are not covered for contracts of a personal nature, and it has promised FAQs, so his exact position will be clear only when those FAQs come out. Businesses that bill foreign clients, such as a design studio working for a London agency or an engineering firm preparing drawings for a Dubai contractor, should plan to file.

RBI's new Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 came into force on 1 October 2026. On 22 September, nine days before the start date, RBI cut the time allowed to bring export money home back to nine months. Here is what has changed, in plain terms, and what exporters should do now.

In short: The 2026 regulations (Notification No. FEMA 23(R)/2026-RB dated 13 January 2026) replaced the 2015 export regulations from 1 October 2026. Service exporters, including software exporters, must declare their export invoices in an Export Declaration Form (EDF) within 30 days from the end of the month in which the invoice was raised. One EDF can cover all invoices of a month. For services other than software, the EDF may instead be filed on or before the date the payment is received. SOFTEX forms are gone. Goods exporters continue to furnish the EDF at the time of shipment. Under the amendment of 22 September 2026 (Notification No. FEMA 23(R)/(1)/2026-RB), export proceeds must be realised within nine months, or twelve months for exports invoiced or settled in rupees. Where an invoice or shipping bill is up to Rs 10 lakh, the bank can close the entry on the exporter's own declaration.

Who has to file an EDF now?

For goods, not much changes. The EDF is furnished at the time of shipment, along with the shipping bill, as before. The real change is for services. Until now, only software exporters filed a declaration, through SOFTEX, and most other service exporters simply received the money and collected a FIRA. From October, exporters of services declare their exports to the bank through the EDF. This clearly covers businesses such as:

IT, software and SaaS businesses, and global capability centres
Consultants and freelancers who run their work as a business: developers, designers, writers, editors and engineers (see the note below)
Digital marketing agencies, KPOs and back-office service providers
Professional firms that bill foreign clients

A note on individuals: on 7 October 2026, RBI said individuals are not covered by the reporting requirement for contracts of a personal nature. RBI will explain what that covers in its FAQs, which had not been issued by 10 October 2026. Until then, the written rule has not changed.

EDF for export of services: how does it work?

One form or many: you may put all export invoices of a month into a single EDF, even for different clients, or file a separate EDF for each invoice.
Deadline: within 30 days from the end of the month in which the invoice was raised. For services other than software, the rules also allow filing on or before the date the payment is received. RBI has not explained how this option fits with the 30-day limit, so file within 30 days to be safe.
Where to file: with your authorised dealer bank, normally the bank through which the export money is received. SEZ units file with the SEZ Development Commissioner. Software exporters outside SEZs can file with their bank or with STPI, which forwards it to the bank.
What goes in it: your PAN and your bank's AD code (and GSTIN and IEC if you have them), and for each invoice the foreign client's name, address and country, invoice number and date, currency, amount, net realisable value, a description of the service and its SAC code. You, or an authorised signatory, sign a declaration that the full value will come in through the bank within the time allowed.
What happens next: the bank records your EDF in EDPMS, RBI's export monitoring system, within five working days. When the payment arrives, the bank matches it to the entry and closes the entry once the full value is received. If you need an eBRC, you generate it yourself on the DGFT portal against the inward remittance details your bank sends to DGFT.
Payment platforms: platforms such as Skydo and Xflow say they do not file the EDF for you. They give you a FIRA and payment details, and the EDF goes to the bank where your payout lands. RBI has not yet said how platform receipts should be declared, so confirm the process with your bank.

Banks set their own procedures, and must publish the main features on their websites. SBI's customer guide, for example, asks for a request letter in its format with FEMA declarations, the agreement or statement of work, the invoices, the EDF and proof that the service was provided, and certifies the EDF in one working day.

EDF filing deadline: the dates

Invoices raised in October 2026: by 30 November 2026
Invoices raised in November 2026: by 30 December 2026
Invoices raised in December 2026: by 30 January 2027
Invoices dated up to 30 September 2026: the old rules apply. In our reading no EDF is needed for them; RBI's FAQs should confirm this.

If you are late, ask your bank for more time and give reasons, because the bank can extend the period. Your bank cannot charge you a penalty for a regulatory delay.

Nine months, not fifteen

The January 2026 regulations had allowed fifteen months to realise export proceeds. The 22 September amendment took it back to nine months before the new rules even started:

Goods: nine months from the date of shipment.
Services: nine months from the date of the invoice.
Exports invoiced or settled in rupees: twelve months.

If a buyer is slow to pay, ask your bank for an extension before the period runs out, with the reason and your correspondence with the buyer. Banks can now grant extensions, allow a reduction in the export value (including an amount that will never be paid), and permit set-off against import payments to the same overseas party or its group companies, without going to RBI. Do not leave it too long: if export money is still unpaid more than one year after the due date, or after any extended date the bank allowed, further exports are allowed only against full advance payment or an irrevocable letter of credit.

The Rs 10 lakh relief for small exporters

Where an invoice (for services) or shipping bill (for goods) is Rs 10 lakh or less, the bank can close the EDPMS entry on your own declaration that the payment has been received, in full or otherwise, and you can give this declaration once a quarter for many entries together. A reduction in value of up to Rs 10 lakh per invoice can also be allowed on your declaration. Most small agencies invoice well within this limit, so for them this is the most useful part of the new rules. It only helps if the EDF was filed in the first place.

Why this matters beyond FEMA

GST: a service is a zero-rated export only if the payment comes in convertible foreign exchange, or in rupees where RBI permits. If you export under an LUT and the payment does not come within the time allowed under the GST rules, IGST with interest can be demanded. This GST time limit is separate from the nine-month FEMA limit. Our note on billing foreign clients as a freelancer explains the GST side and the LUT.
Refunds and incentives: a GST refund claim for exported services needs invoice-wise proof that the money came in, such as a BRC, eBRC, FIRC or FIRA. Since 13 January 2026, an eBRC must also show your GSTIN and GST invoice number and date, so keep invoices, EDFs and payment advices matched. See why export GST refunds get stuck.
Penalty: under FEMA, a contravention can attract, after adjudication, a penalty of up to three times the amount involved, or up to Rs 2 lakh where the amount cannot be quantified, plus up to Rs 5,000 for every day after the first while it continues.

GST changes for exporters from the 57th GST Council

On 8 October 2026, the GST Council also recommended changes that help exporters. They need amendments to the GST law, and the Finance Minister said the process reforms are targeted for implementation from 1 April 2027:

For export refund claims the system rates as low-risk, 90% of the amount claimed to be sanctioned provisionally by the system, with the order within three working days of acknowledgement
Services to your own branch abroad to count as exports, by removing the "distinct person" condition
Rule 96(10) to be omitted from 23 October 2017, which helps goods exporters whose IGST refunds were denied because they had used import or input tax concessions such as Advance Authorisation or EOU benefits
Refund of input tax credit on capital goods, spread over 60 months, for credit taken from 1 April 2027, where you export under LUT or bond or have an inverted duty structure
A circular on receiving export payments in foreign exchange or in rupees

What to do now

Tell your bank that you export services, and ask how it wants the EDF: on paper, by email or through its portal.
List every export invoice from October onwards, with its SAC code, buyer and currency.
File the October EDF by 30 November, and set a monthly reminder for the 30-day deadline.
Match each payment to its invoice, and follow up on anything older than six months.
For exports made before 1 October 2026, the old 2015 rules still apply. Since November 2025 those rules allowed fifteen months to bring the money in, so check each older invoice or shipment separately. Banks can now give the approvals for these older exports that earlier needed RBI.
If you also import from the same overseas party or its group companies, ask the bank about setting off payables against receivables within the realisation period.

New to exporting? Our guide to starting exports from Gujarat covers IEC, the AD code and LUT in order.

What we do for you

Tell you exactly what the new rules require for your kind of export
Prepare the EDF and coordinate with your bank
Reconcile EDPMS entries with invoices, payments and FIRAs
Apply for extensions, reductions or set-off through your bank
Handle LUT, GST returns and export refunds
Clean up old open entries before they turn into a problem

Gadhia Associate has been in practice since 2007 and has handled work for over 7,000 clients across Saurashtra and Gujarat, with a 5.0 Google rating from more than 100 reviews. Software exporters, freelancers, agencies and manufacturers from Junagadh, Rajkot, Jamnagar, Morbi, Porbandar and Veraval come to our Junagadh office, where same-day appointments are available. FEMA and GST work for exporters is handled online, so we also work with exporters anywhere in India. Fixed-fee and monthly plans are available.

Export services or goods? Get your first EDF right. Call or WhatsApp +91 82005 28355, or message us on WhatsApp. The first consultation is free.

Frequently asked questions

What is EDF under FEMA?

EDF is the Export Declaration Form, the declaration an exporter makes about goods or services exported, so that the bank can track the export until the money is received.

Is EDF required for export of services?

Yes, from 1 October 2026 exporters of services declare their invoices to their bank in an EDF. RBI said on 7 October that individuals are not covered for contracts of a personal nature, and its FAQs on this are awaited.

Do freelancers have to file an EDF?

It depends. The written rule covers every exporter of services, but on 7 October 2026 RBI said individuals are not covered for contracts of a personal nature and promised FAQs to explain this. If you freelance as a business, for example with GST registration, an LUT and regular foreign clients, ask your bank and keep your EDF ready until the FAQs settle the point.

What is the due date for the EDF for services?

Within 30 days from the end of the month in which the invoice was raised, so October 2026 invoices are due by 30 November 2026. For services other than software, the rules also allow filing on or before the date the payment is received, and your bank can extend the time if you give reasons.

Is the SOFTEX form still required?

No. The SOFTEX form ended on 30 September 2026. Software exports are now declared in the EDF, which you can file with your bank or with STPI, or with the Development Commissioner if you are in an SEZ. Software exporters must file within 30 days from the end of the month.

What is the export realisation period from 1 October 2026?

Nine months from shipment for goods and from the invoice date for services, and twelve months for exports invoiced or settled in rupees.

What if my foreign client pays late?

Ask your bank for an extension before the nine months end, with the reason and supporting correspondence. Banks can now grant it without going to RBI.

I am paid through PayPal, Wise or Payoneer. Do I still need an EDF?

The platform does not file it for you. What matters is whether the money is payment for a service supplied abroad, not the app it comes through. The EDF goes to the bank where your payout lands, and RBI has not yet addressed platform receipts, so confirm the process with your bank.

Position as of 10 October 2026. RBI has said it will issue FAQs on the new reporting rules; they had not been issued on this date. Each bank sets its own procedure for the EDF, so formats and filing channels differ from bank to bank. Exports made before 1 October 2026 follow the earlier rules. Take advice on your own contracts and entries.