--- title: "Export Declaration Form (EDF) for service exports from 1 October 2026" seoTitle: "EDF for service exports from 1 October 2026" description: "New RBI export regulations ask service exporters to declare their invoices to the bank every month. See the deadline, what the form asks for, what RBI has said about individuals, and what changes for your LUT and refund records." seoDescription: "Service exporters now declare invoices to their bank in an EDF. Deadline, form fields, RBI's remarks on individuals, and the effect on GST LUT and refunds." topic: "Declare service exports" published: 2026-10-22 checked: 2026-10-22 order: 39 --- **From 1 October 2026, an exporter of services declares the full export value of its invoices to its bank in an Export Declaration Form (EDF), within 30 days from the end of the month in which each invoice is raised. One EDF can cover all of a month's service exports.** [Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, regulations 1(2) and 3(2)](https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13277&Mode=0). The EDF is a foreign exchange (FEMA) requirement, separate from GST. It does not replace your LUT, your GST returns or the bank evidence in Statement 3. It describes the same invoices, so prepare all of them from one invoice register. ## Who has to file an EDF The Regulations apply to every exporter of services. They contain no exemption by amount or by type of exporter. When RBI published them in January 2026, it declined requests to exempt service exports, citing section 7 of FEMA, which makes declaration of exports mandatory. [RBI press release of 16 January 2026 and its statement on feedback received](https://www.rbi.org.in/Scripts/BS_PressReleaseDisplay.aspx?prid=62049). At RBI's press conference on 7 October 2026, the Governor said individuals providing services abroad, such as tutoring or small software work, are not required to report, irrespective of the amount. A Deputy Governor described this as covering contracts of a personal nature and said RBI would clarify it in FAQs. [RBI: edited transcript of the press conference](https://www.rbi.org.in/Scripts/BS_SpeechesView.aspx?Id=1583). As of 22 October 2026, RBI has not published those FAQs or amended the Regulations. The remarks also do not say whether a sole proprietor or a GST-registered freelancer counts as an individual for this purpose. Until RBI publishes the FAQs: - A company, LLP or partnership firm exporting services should file the EDF. - An individual or sole proprietor should ask the bank that receives the payments whether it requires an EDF. Keep the invoice details ready either way. ## When and where to submit it | Your exports | Submit to | Deadline | | --------------------------------------------- | ------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------- | | Services other than software | Your authorised dealer (AD) bank; an SEZ unit submits to its Development Commissioner | Within 30 days from the end of the invoice month, or on or before the date you receive payment | | Software | Your AD bank or Software Technology Parks of India (STPI) | Within 30 days from the end of the invoice month | | Several clients or invoices in the same month | One EDF can cover them all | The same deadline | The bank can extend the deadline if you ask and give reasons. [Regulations 2(1)(f) and 3(2)](https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13277&Mode=0). For example, a consulting firm invoices one client in the United States on 4 November 2026 and another in Germany on 27 November 2026. It can submit one EDF covering both invoices by 30 December 2026, 30 days after the end of November. The Regulations define software broadly: "any computer programme, database, drawing, design, audio/video signals, any information by whatever name called" held on a non-physical medium. If you deliver designs, video or data files online, ask your bank which category it applies to your exports. The option to submit on or before the date of payment is available only for services other than software. ## What the form asks for The EDF is set out in the Annex to the Regulations. Its services section has one row for each invoice, with: - the recipient's name, address and country - the invoice number, date, currency and amount, and the net realisable value - the contract number and date, if any - a description of the services and the SAC The general section asks for your GSTIN, PAN, Importer-Exporter Code (IEC), name and address, the bank's AD code and the delivery mode, which includes "Internet". [EDF, Annex to the Regulations](https://rbidocs.rbi.org.in/rdocs/content/pdfs/Gazette15012026.pdf). If you have no IEC, ask your bank what it accepts before the deadline. Take every entry from the records behind your GST export invoices and GSTR-1: - Use the invoice numbers and dates exactly as they appear on the tax invoice. - Use the same SAC as on the invoice. - Declare the full export value of each invoice, as regulation 3(2) requires. Your bank may have its own format or online form. Each AD bank must publish its policy for these transactions, including documents, timelines and charges, and the main features of its procedure on its website. [Regulation 19(1) and (4)](https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13277&Mode=0). CA Jeevan Jot Singh [summarised one bank's published EDF procedure](https://x.com/CAausticT/status/2109901317103853728) on X. ## What the bank does with the EDF The bank enters your EDF in RBI's Export Data Processing and Monitoring System (EDPMS) within five working days. It records the inward remittances against your exports and marks each entry off once the export value has been realised. [Regulation 18(1)(b), (e) and (g)](https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13277&Mode=0). For an invoice of up to ₹10 lakh, the bank can close the EDPMS entry on your declaration that the payment has been realised, in full or otherwise. You can also give the bank one quarterly declaration to close such entries in bulk. [Regulation 4(2), proviso](https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13277&Mode=0). This is the self-declaration for bills up to ₹10 lakh that the Governor mentioned on 7 October. It closes the entry after payment. It does not replace the EDF. If a cross-border payment aggregator collects the payment, its limit is ₹25 lakh for each transaction, and it must give your bank the documents needed to close the EDPMS entry. [RBI Master Direction on Payment Aggregators, paragraph 11(d) and (h)](https://www.rbi.org.in/Scripts/BS_ViewMasDirections.aspx?id=12896). The bank may not charge you a fee or penalty for a regulatory delay or breach on your part. [Regulation 19(3)](https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13277&Mode=0). ## How long you have to receive payment | Rule | Period for services | | ----------------------------------------------------- | -------------------------------------------------------------------------------------------- | | Usual period | Nine months from the invoice date | | Invoice raised or settled in Indian rupees | Twelve months from the invoice date | | Payment late for a genuine reason | The bank can extend the period on your request | | Client will not pay in full | The bank can allow a reduction or write-off; up to ₹10 lakh per invoice, on your declaration | | Unpaid for over a year after the due or extended date | Further exports only against full advance payment or an irrevocable letter of credit | These periods apply from 1 October 2026. RBI shortened them from fifteen and eighteen months by an amendment of 22 September 2026, before the Regulations took effect. [Regulations 5, 6 and 13, with the amendment](https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13714&Mode=0). For an invoice raised before 1 October that is still unpaid, ask your bank which period it applies. ## What it changes for your GST LUT and refund **The LUT payment deadline.** Under an LUT, if payment for an export of services does not arrive, the tax falls due 15 days after the later of one year from the invoice date or the period allowed under FEMA, including any RBI-permitted extension. The Commissioner can allow more time. [CGST rule 96A(1)(b), as substituted by Notification 12/2024-Central Tax, clause 20](https://www.gstcouncil.gov.in/sites/default/files/2024-09/central-tax-12-2024-11072024.pdf#page=7). The FEMA period for services is now nine or twelve months, so for invoices from 1 October 2026 the one-year period is normally the later one. For example, if an invoice dated 15 October 2026 is still unpaid, FEMA's nine months end in mid-July 2027, but the GST deadline is 15 days after one year from the invoice date, at the end of October 2027. That changes only if realisation is extended beyond a year. A reduction or write-off that the bank allows under FEMA is not receipt of payment. If the payment never arrives, the LUT still requires the tax and interest. See [LUT filing for service exporters](/guides/lut-for-service-exporters/#what-if-the-overseas-customer-has-not-paid). **Statement 3 evidence.** The EDF is not a BRC or FIRC. Statement 3 still needs the bank realisation or remittance certificate for each receipt. RBI's January 2026 directions to banks superseded its earlier circulars from 1 October 2026, including the 2017 circular on issuing electronic BRCs, and did not restate it. [A.P. (DIR Series) Circular No. 20, paragraph 4 and Annex](https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13278&Mode=0). If an eBRC you expect for a receipt does not appear in DGFT, ask your bank for its own remittance certificate. See [FIRC and bank evidence for a refund](/guides/firc-bank-export-services/). **One set of figures.** The same invoices now appear in GSTR-1, in Statement 3 and in the EDF. Pratibha Gupta [pointed out on X](https://x.com/PratibhaGoyal/status/2107331038536216621) that for service exporters, GST returns should now reconcile with the EDF. ## A monthly routine 1. At the end of each month, list the export invoices raised in it from your invoice register. 2. Check each invoice's number, date, value and SAC against what you report in GSTR-1. 3. Submit one EDF to your bank, or STPI for software, within 30 days after the month ends, and keep the acknowledgement. 4. When a payment arrives, give the bank the invoice numbers it settles. For invoices up to ₹10 lakh, give the realisation declaration, or one each quarter. 5. Get the remittance certificate or eBRC for each receipt and record it against the invoices it settles. 6. For each unpaid invoice, track both dates: nine months for FEMA and one year plus 15 days for GST. The bank evidence from step 5 is what goes into Statement 3. Use the [Statement 3 worked example](/guides/statement-3-worked-example/) to match receipts to invoices for the refund claim.