According to a BusinessLine report, some banks have stopped insisting on EDFs from individuals receiving overseas payments for services, while others continue to treat the original RBI circular as the operative instruction and require filings irrespective of whether the exporter is a registered business.
The confusion came into sharper focus after a popular marketer reported on social media that his bank had asked him to complete an EDF for foreign exchange received for consulting services. The request raised questions about whether individuals should have to navigate a detailed, multi-spreadsheet declaration to receive payments for services rendered overseas.
What do the new RBI rules require?
The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, which took effect on October 1, require service exporters to submit an EDF declaring the full export value of their services under Regulation 3(2).
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Generally, the declaration must be submitted within 30 days from the end of the month in which the service invoice is raised. A single declaration may cover services supplied to one or more recipients during a month. For services other than software, an EDF may also be submitted on or before receipt of payment. Authorised dealer banks can extend the filing period for justified reasons.
Malhotra has also indicated that small exporters can submit a self-declaration instead of uploading an invoice for transactions of up to ₹10 lakh per bill. However, this is a documentation concession and does not automatically exempt a transaction from EDF reporting.
Banks await clarity as exporters seek relief
The uncertainty has been compounded by the incomplete rollout of reporting procedures. The RBI had directed authorised dealer banks to publish standard operating procedures (SOPs) explaining the new process, but a BusinessLine analysis found that only two of the 19 listed banks had published them.
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India SME Forum has sought a 90-day suspension of recurring EDF filings for micro and small service exporters while a simpler reporting mechanism is developed. The request remains an industry proposal and has not been approved.
Separately, the new framework has shortened the period for realising and repatriating export proceeds from 15 months to nine months. For exports invoiced or settled in Indian rupees, the period has been reduced from 18 months to 12 months, effective October 1.
These deadlines are separate from EDF filing requirements, meaning exporters must track both their declaration obligations and the timelines for bringing export proceeds into India.
Until the RBI issues formal clarification, individual service exporters should seek written guidance from their authorised dealer banks, reconcile invoices with remittance records, check payment purpose codes and maintain supporting documentation.
The lack of uniform instructions risks increasing compliance costs for freelancers and small businesses earning foreign exchange from services, even as they await clarity on how the new framework applies to them.
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