EDF for Freelancers: The New Monthly RBI Filing for Foreign Invoices from 1 October 2026

If you invoice clients outside India, there is a new monthly filing starting next week, and it lands on you rather than on your client.

Until now, a freelance developer or designer billing a US client in dollars had nothing to declare to RBI. The money arrived, the bank gave you a FIRA, and that was it. Goods exporters filed an EDF, and software companies filed SOFTEX. Most service freelancers filed nothing.

That ends on 1 October 2026.

TL;DR. Under RBI's FEMA (Export and Import of Goods and Services) Regulations, 2026 (Notification FEMA 23(R)/2026-RB), every exporter of services must file an Export Declaration Form (EDF) with the bank that receives their foreign money, within 30 days from the end of the month in which the invoice was raised. One EDF can cover all of that month's invoices. Your bank logs it in RBI's EDPMS, and the entry stays open until the payment arrives. You now have 15 months from the invoice date to get paid in foreign currency (18 months if invoiced in rupees), up from 9. Your GST LUT deadline is still one year.

This is an explainer, not legal or tax advice. The regulation is short and each bank writes its own procedure, so confirm the details with your bank.

What the rule actually says

Regulation 3(2) is one sentence with three provisos. The exporter of services shall furnish an EDF "specifying the amount representing the full export value of services, within 30 days from the end of month in which invoice for services has been raised", and:

• a single EDF may cover all exports to one or more recipients in that month;
• for services other than software, the EDF may instead be filed on or before the date the payment arrives;
• the bank may extend the deadline if you ask and give a reason.

The regulation also says "services" include software. The two terms are no longer treated separately.

Who you file with is set in Regulation 2: for services, including software, it is your Authorised Dealer bank, the bank where the foreign money is credited. Your bank then has five working days to enter it into EDPMS.

The deadline, concretely

Invoices dated before 1 October fall under the old rules.

Don't rely on the "file on payment date" option. It only applies to services other than software, and RBI defines software as "any computer programme, database, drawing, design, audio/video signals, any information by whatever name called" that isn't on a physical medium. Code, UI designs, illustrations, edited video and written deliverables sent over the internet can all fall inside that definition. The 30-day monthly deadline is the safe default.

What gets easier

• More time to get paid. Foreign-currency invoices now have 15 months from the invoice date, and rupee invoices have 18 months. It was 9 months.
• Small invoices close on your word. For any invoice up to ₹10 lakh, the bank can close the EDPMS entry on your declaration that it was paid. You can send these declarations quarterly, in bulk.
• Short payments are simpler. If a client paid less than the invoice, or never paid, you can reduce the value of any invoice up to ₹10 lakh by declaration. Platform fees and a client who disappears both count.
• Third-party payments are allowed. If a client pays through a parent company or someone else, the bank can accept it once it is satisfied the payment is genuine.
• Banks can't penalise you for your own delay. Regulation 19(3) says charges must be "reasonable and proportional" and bars banks from levying "any charges or penalty" for a regulatory delay by the customer.

The trap: 15 months under FEMA is not 15 months under GST

If you export under a GST LUT, Rule 96A still requires the payment within one year of the invoice. Otherwise you owe the IGST you didn't charge, with interest. RBI extending its window to 15 months doesn't change the GST rule. Keep treating twelve months as your real deadline.

What your bank still has to tell you

The regulation leaves the form mechanics to each bank, and several things are unsettled:

• GSTIN and PAN. Axis Bank's summary of the new rules says both are mandatory for the EDF. The regulation text itself doesn't mention GSTIN. If you're under the ₹20 lakh GST threshold and not registered, ask your bank what it will accept.
• Where to file. Some banks will use a trade portal and others will take it at the branch. Ask where and in what format.
• Payment platforms. If Skydo, Wise or Payoneer collect for you and then pay into your Indian account, ask the platform which bank is your AD and whether it links your EDF to the incoming payment. Every guide I've read says the filing is still yours.

The practical step this week: email your relationship manager or bank branch and ask for its EDF procedure for service exports. RBI requires every AD bank to publish its policy and the main features of its SOP on its website.

What you'll need each month

For every foreign invoice in the month:

• invoice number and date
• client name and country
• currency and amount
• a description of the service

Separately, your GSTIN (if registered) and PAN.

If your invoices already live in one place, this is a ten-minute job. If they're spread across Word files and email threads, it becomes a monthly chore on top of GSTR-1 and GSTR-3B.

InvoiceRocket will generate your EDF report

We're adding a monthly EDF report to InvoiceRocket. Pick a month and it lists every export invoice with the fields above, totalled by currency, ready to hand to your bank. It will also track which invoices are paid, so you can see which EDPMS entries you can close by declaration and send them in your quarterly batch. Your export invoices already carry the client country, currency, LUT reference and payment status, so the report reuses data you have already entered.

If you invoice foreign clients, start free and have your October invoices ready when the first EDF is due on 30 November.