Do I need to file an EDF? Checker and due dates
Short answer
- Service exporters file one Export Declaration Form (EDF) a month with their bank, within 30 days after the month the invoice was raised (from 1 Oct 2026).
- RBI said on 7 Oct 2026 that individuals on contracts of a personal nature need not report. That is not yet in writing as an FAQ.
- October 2026 invoices: file by 30 Nov 2026.
- Invoices up to ₹10 lakh: the bank can close the entry on your declaration. That is not an exemption from the EDF.
RBI FAQ status: not published as of 17 Oct 2026 (checked on rbi.org.in). No suspension of EDF filing has been announced.
EDF due dates, month by month
One EDF per month of invoices, due 30 days after month-end (Regulation 3(2)). Payment for services must be realised within nine months from the invoice date (Regulation 5, as amended).
| Invoices raised in | File one EDF by | 9-month realisation, invoice dated the 1st |
|---|---|---|
| October 2026 | 30 Nov 2026 | 1 Jul 2027 |
| November 2026 | 30 Dec 2026 | 1 Aug 2027 |
| December 2026 | 30 Jan 2027 | 1 Sep 2027 |
| January 2027 | 2 Mar 2027 | 1 Oct 2027 |
| February 2027 | 30 Mar 2027 | 1 Nov 2027 |
| March 2027 | 30 Apr 2027 | 1 Dec 2027 |
| April 2027 | 30 May 2027 | 1 Jan 2028 |
| May 2027 | 30 Jun 2027 | 1 Feb 2028 |
| June 2027 | 30 Jul 2027 | 1 Mar 2028 |
Who is exempt? What we know on 17 Oct 2026
| Your situation | What the rules and RBI say | What to do now |
|---|---|---|
| Individual on a contract of a personal nature (RBI's examples: tutoring, small software work) | RBI said on 7 Oct 2026 these individuals are not required to report. Said at a press conference; not yet in an FAQ or amendment. | Ask your bank to confirm in writing. |
| Freelancer billing in own name, ongoing business-like work | Unclear. The Regulations have no individual exemption; RBI's words were limited to contracts of a personal nature. | Ask your bank what it needs. Keep invoices and FIRAs. |
| Proprietor, GST-registered or trading name | Likely covered by the Regulation text; no exemption announced. | Plan to file monthly unless your bank says otherwise. |
| Partnership firm, LLP or company | Covered. | File one EDF a month through your AD bank. |
| Any invoice up to ₹10 lakh | Not an exemption. The bank may close the EDPMS entry on your declaration that payment was realised, or a quarterly bulk declaration. | Prepare a realisation declaration; ask your bank for its format. |
| Services other than software | Covered, but you may file on or before the day payment is received instead. | Use whichever route your bank supports. |
| Paid via PayPal, Payoneer, Wise, Skydo, a merchant of record or AdSense | No official guidance. Users report banks treating these differently. | Ask the bank that credits your rupees; don't assume the platform files for you. |
Next: 30 Nov checklist, bank holding your payment, full EDF FAQ and changelog.
Questions
Do I need to file an EDF for every invoice?
No. Regulation 3(2)(a) lets a service exporter file a single EDF for all of a month's exports, within 30 days from the end of that month.
What is the EDF due date for October 2026 invoices?
30 November 2026: 30 days from 31 October. For services other than software you may instead file on or before the day payment is received.
Is the ₹10 lakh self-declaration an exemption?
No. The Regulations let the bank close the EDPMS entry for an invoice up to ₹10 lakh on your declaration that payment was realised. RBI's Governor called it an alternative to detailed reporting, not an exemption.
Do I need an EDF for PayPal or Payoneer payments?
There is no official guidance yet. Ask the bank that credits your rupees whether it wants an EDF from you.
Sources
- RBI, FEMA (Export and Import of Goods and Services) Regulations, 2026, FEMA 23(R)/2026-RB, amended to 22 Sep 2026: www.rbi.org.in
- RBI, Amendment Regulations, FEMA 23(R)/(1)/2026-RB, 22 Sep 2026: rbi.org.in
- RBI, A.P. (DIR Series) Circular No. 20, 16 Jan 2026: www.rbi.org.in
- RBI, Frequently Asked Questions index (checked 17 Oct 2026: no EDF FAQ listed): www.rbi.org.in
- Economic Times, 7 Oct 2026: RBI says individuals need not report; FAQs to follow: economictimes.indiatimes.com
- Business Today, 7 Oct 2026: framework does not apply to individuals: www.businesstoday.in
- Mint: RBI clarifies what freelancers and small exporters need to report: www.livemint.com
- Mint: New FEMA rules for foreign payments, what freelancers need to know: www.livemint.com
- FEDAI Special Circular SPL-07/Trade/2026, 23 Sep 2026: fedai.org.in