FEMA & RBI

EDF Form: How to File the Export Declaration Form (2026)

Since 1 October 2026 every exporter of services and software files a monthly Export Declaration Form (EDF) under FEMA. Who files it, where, the due dates, the nine month realisation rule and what a missed EDF costs.

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FEMA & RBI

CA NandiniCo-founder

24 Sep 2026Published

Reviewed by Nihal Srivastava24 Sep 2026

13 minute read11 questions answered at the end

Krystal7 Consultants · India entry, tax and compliance

EDF Form: How to File the Export Declaration Form (2026)

Written by CA Nandini, Krystal7 Consultants. Last updated 1 October 2026.

The Export Declaration Form (EDF) is the form an Indian exporter uses to declare the full value of an export under FEMA. Since 1 October 2026, every exporter of services and software files one, usually once a month. It goes to the AD bank within 30 days from the end of the month in which the invoices were raised. The money must reach India within nine months of the invoice date. The rule comes from RBI notification FEMA 23(R)/2026-RB dated 13 January 2026.

Until 30 September 2026, EDF was mainly a goods form, and most service exporters filed no declaration at all. Software exporters filed SOFTEX. The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 changed that from 1 October 2026. This guide answers the questions we hear most from founders and finance teams.

AI Overview Summary

From 1 Oct 2026 every exporter of goods, services or software in India declares the full export value on an Export Declaration Form under FEMA 23(R)/2026-RB. SOFTEX is discontinued for invoices from that date.
A service or software exporter files one EDF a month for all that month's invoices, within 30 days of the month end, so October 2026 invoices are due by 30 Nov 2026.
Export proceeds of services must reach India within nine months of the invoice date, or twelve months where the export is invoiced or settled in rupees. The AD bank may extend either period.
An EDF goes to the AD bank for services, the AD bank or STPI for software and Customs for goods. At an EDI port the shipping bill on ICEGATE counts as the goods EDF.
Missing the EDF deadline breaches regulation 3(2), a FEMA contravention. A section 13 penalty on adjudication can reach three times the sum involved, or INR 2 lakh where it cannot be quantified.

What is the EDF form?

The EDF is the export declaration prescribed in the Annex to the 2026 Regulations. The exporter uses it to state the full export value of goods, services or software to a "specified authority". That authority is Customs, the AD bank, STPI or an SEZ Development Commissioner, depending on what you export and from where.

The declaration starts the monitoring trail. The AD bank records it in EDPMS, the Export Data Processing and Monitoring System. The entry stays open until the export value reaches India. When the money arrives, the bank closes the entry.

Who needs to file an EDF?

Any person in India who exports goods, services or software, from 1 October 2026. For service businesses, that includes:

Indian subsidiaries billing a foreign parent for development, support or back office work
IT and IT enabled services companies billing overseas clients
Consultants, agencies and freelancers invoicing clients abroad
Global capability centres billing group companies
SEZ units exporting services or software

Regulation 2 of the 2026 Regulations treats software as a service for these rules. So a software company files the same EDF as any other service exporter.

Where do you file the EDF?

It depends on what you export and where your unit sits. The 2026 Regulations define the specified authority as follows.

What you export	Unit in the domestic tariff area	Unit in a SEZ
Goods	Commissioner of Customs	Development Commissioner of the SEZ
Services other than software	AD bank	Development Commissioner of the SEZ
Software	AD bank or STPI	Development Commissioner of the SEZ

The AD bank is the bank that handles your export receipts. If you file with STPI or a SEZ, that authority forwards the authenticated EDF to your AD bank, under regulation 3(3).

The regulations do not name a portal for service EDFs. Each bank sets its own format and route, such as its trade portal, email or a branch submission. Ask your bank for its process in writing before your first due date.

When is the EDF due?

For services and software, within 30 days from the end of the month in which you raised the invoice. That comes from regulation 3(2) of the 2026 Regulations. One EDF can cover all your export invoices of that month, to one client or many.

Invoices raised in	EDF due by
October 2026	30 November 2026
November 2026	30 December 2026
December 2026	30 January 2027

Two further options sit in the provisos to regulation 3(2):

An exporter of services other than software may file the EDF on or before the date it receives payment.
The AD bank may extend the time to file, if the exporter asks and gives reasons the bank accepts.

For goods, the EDF is due at the time of export. At an EDI port the shipping bill filed on ICEGATE counts as the EDF, so there is no separate form.

How do you file an EDF step by step?

Here is the monthly routine we run for service and software clients.

Confirm the category. Check whether each invoice is for goods, software or other services. This decides the authority and the timing.
Keep an export invoice register. Record invoice number, date, client name and country, currency, amount and a short description of the service.
Close the month. On the first working day of the next month, lock the list of export invoices raised in the month just ended.
Prepare one EDF. Fill the form in your bank's format with the full export value of every invoice in the register for that month.
Sign and submit. File it with the AD bank, or with STPI for software, within 30 days after the month end.
Get the acknowledgement. Keep the bank's receipt. Under regulation 18, the bank enters service EDFs in EDPMS within five working days of receipt.
Match the money. When a client pays, give the bank the invoice numbers the payment covers. The bank matches the inward remittance and marks off the entry.
Review open entries. Each month, list invoices still unpaid and their nine month realisation dates. Act before an entry goes overdue.

Once the bank has realised the proceeds, you can generate the electronic bank realisation certificate (eBRC) on the DGFT platform where you need one.

What documents do you need for an EDF?

Your bank decides the exact list. In our experience, keep these ready each month:

Copies of all export invoices raised in the month
The export invoice register for the month
The contract or services agreement with each client, the first time you bill them
Your LUT acknowledgement for zero rated GST exports, where the bank asks for it
Payment advice for any advance received against those invoices

After payment, the bank issues a Foreign Inward Remittance Advice (FIRA) or a similar record. Keep it with the invoice. The same trail supports your GST refund claims, which we cover in our guide to GST on export of services.

A FEMA transaction of INR 50 crore or more needs a Legal Entity Identifier, which our guide to LEI registration in India explains.

How does EDF for software and services differ from goods?

The form is the same, but the timing and the authority differ.

Point	Goods	Services and software
When to file	At the time of export	Within 30 days from the end of the invoice month
Filed with	Customs, through the shipping bill at EDI ports	AD bank; STPI is also an option for software
One form covers	One shipment	All invoices of the month
Realisation period	Nine months from the date of shipment	Nine months from the invoice date
Rupee invoicing or settlement	Twelve months	Twelve months

The realisation periods come from regulation 5, as amended by FEMA 23(R)/(1)/2026-RB dated 22 September 2026. They apply to exports made from 1 October 2026. Goods exported to a warehouse outside India get nine months from the date of sale from the warehouse.

What is the realisation period for export of services from 1 October 2026?

Nine months from the invoice date, under regulation 5(1)(a) of the 2026 Regulations. Where the export is invoiced or settled in Indian rupees, the period is twelve months from the invoice date. The AD bank may extend either period on the exporter's request, if it accepts the reasons.

The January 2026 text of regulation 5 gave fifteen months, and eighteen months for rupee exports. FEMA 23(R)/(1)/2026-RB dated 22 September 2026 replaced these with nine and twelve months. The Gazette published it on 24 September 2026. It came into force on 1 October 2026, the same day as the regulations, so the longer periods never applied.

Exports made up to 30 September 2026 stay under regulation 9 of the 2015 Regulations, which gives nine months from the date of export. Ask your AD bank which period it has recorded for each older entry.

What happens if you miss the EDF deadline?

Without the EDF there is no EDPMS entry, so the bank cannot match the client's payment to an export. A missed EDF is a breach of regulation 3(2), which is a contravention under FEMA.

Section 13 of FEMA sets the penalty on adjudication. It can reach three times the sum involved where the amount is quantifiable, or INR 2 lakh where it is not. A continuing breach can add up to INR 5,000 for each day after the first.

In practice, act in this order:

File the late EDF at once and ask the bank to extend the time under the third proviso to regulation 3(2), with your reasons.
If the bank refuses, or the gap is large, look at compounding with the RBI. Our FEMA compounding guide explains that route.

Unpaid invoices carry a separate risk. Regulation 13 covers proceeds still unrealised one year after the due date. From then on, you can export only against full advance or an irrevocable letter of credit.

What if a client pays less, or does not pay?

Ask the AD bank for a reduction. Regulation 6 lets the bank allow a reduction in the export value, including full non realisation, if it accepts your reasons. For invoices up to INR 10 lakh, the bank may allow it on your own declaration.

The 2026 Regulations contain no separate write off provision. The reduction route under regulation 6 now covers the cases that exporters used to write off.

Two other routes help:

Extension. The bank may extend the realisation period beyond nine months, or twelve for rupee exports, if it accepts your reasons, under regulation 5.
Set off. Under regulation 7, the bank may allow you to set off export receivables against import payables with the same overseas party, or its group companies, within the realisation period.

Our guide on how to set off export receivables against import payables explains the regulation 7 route in more detail.

How is EDF different from SOFTEX?

SOFTEX was a software declaration filed for each invoice with STPI or the SEZ. The EDF covers all service and software exports of a month in one form, and the AD bank can receive it. SOFTEX is discontinued for exports invoiced from 1 October 2026. Invoices dated up to 30 September 2026 still need SOFTEX. The details are in our note on the SOFTEX form being discontinued.

Point	SOFTEX	EDF
Applies to	Software invoiced up to 30 September 2026	All exports from 1 October 2026
Filed with	STPI or SEZ	AD bank, STPI or SEZ
Frequency	Each invoice	One form a month
Due date	30 days from the invoice date	30 days from the end of the invoice month

What changed in 2026?

Point	Old rule	New rule	Date	Instrument
Declaration for services	No declaration for most services	Monthly EDF within 30 days of the invoice month end	1 October 2026	FEMA 23(R)/2026-RB, regulation 3(2)
Declaration for software	SOFTEX for each invoice	Same monthly EDF as other services	1 October 2026	FEMA 23(R)/2026-RB, regulations 2 and 3(2)
Realisation, 2015 Regulations	Nine months	Fifteen months	13 November 2025	FEMA 23(R)/(7)/2025-RB
Realisation, 2015 Regulations	Fifteen months	Nine months	5 June 2026	FEMA 23(R)/(8)/2026-RB
Realisation, 2026 Regulations	Fifteen months; eighteen in rupees (January text, never in force)	Nine months; twelve in rupees	Notified 22 September 2026, in force 1 October 2026	FEMA 23(R)/(1)/2026-RB
Old transactions needing RBI approval	RBI	AD bank, for transactions made before 1 October 2026	1 October 2026	FEMA 23(R)/(1)/2026-RB, new regulation 20

Exporters on the RBI Caution List on 30 September 2026 stay under the RBI order until they are removed from the list. The proviso to regulation 13 says so.

Key terms

Export Declaration Form (EDF): The declaration an exporter files through its Authorised Dealer bank under the FEMA export regulations, FEMA 23(R)/2026-RB, from 1 Oct 2026. For services, including a true up invoice to a foreign parent, it is due within 30 days from the end of the invoice month. Non software exporters may file by the payment date. It replaced SOFTEX.
Export Data Processing and Monitoring System (EDPMS): EDPMS is the Reserve Bank of India system in which AD banks record exports and the inward remittances that settle them. An export entry stays outstanding until the bank marks it realised. From 1 Oct 2026, FEMA 23(R)/2026-RB sets the realisation period at nine months, or twelve months where the export is invoiced or settled in rupees.
Authorised Dealer (AD) Category I bank: An AD Category I bank is a commercial bank that the Reserve Bank of India authorises under section 10 of FEMA, 1999 to deal in foreign exchange for current and capital account transactions. It receives FDI and export proceeds, checks FEMA filings such as FC-GPR before they reach RBI, holds EEFC accounts and approves most branch and liaison office applications.
SOFTEX form: A declaration for each software export invoice, filed with STPI or the SEZ authority within 30 days of the invoice date under the earlier export regime. It is discontinued for invoices from 1 Oct 2026, when the monthly EDF replaced it. Invoices dated up to 30 Sep 2026 still need SOFTEX.
Electronic Bank Realisation Certificate (eBRC): A certificate on the DGFT portal that links a specific inward remittance to a specific export invoice or shipping bill. Since DGFT Trade Notice 33/2023-24, exporters self certify it by mapping the bank's Inward Remittance Message to the invoice. It needs a linked IEC, follows Appendix 2U of the Handbook of Procedures, 2023 and can be cancelled within 120 days.
Realisation period: The time within which export proceeds must reach India. From 1 Oct 2026, regulation 5(1)(a) of FEMA 23(R)/2026-RB gives nine months from shipment for goods and from the invoice date for services, and twelve months where the export is invoiced or settled in rupees. The AD bank may extend it.
Specified authority: The authority with which an exporter files the EDF under the 2026 export regulations: Customs for goods, the AD bank for services other than software, the AD bank or STPI for software, and the Development Commissioner for a unit in a Special Economic Zone.

See the full glossary

Frequently Asked Questions

What is the full form of EDF?

EDF stands for Export Declaration Form. It is the form in the Annex to the 2026 export regulations, notified by the RBI as FEMA 23(R)/2026-RB.

Is EDF mandatory for export of services?

Yes, since 1 October 2026. Regulation 3(2) requires every exporter of services, including software, to declare the full export value on an EDF.

What is the due date for EDF for services?

Within 30 days from the end of the month in which you raised the invoice. For invoices raised in October 2026, the due date is 30 November 2026.

Can I file one EDF for many invoices?

Yes. A service exporter may file a single EDF for all its exports of a month, to one or more clients.

Do freelancers need to file an EDF?

A freelancer who invoices clients abroad is an exporter of services, so the rule applies. Ask your bank how it wants the form from individual exporters.

Is STPI registration needed to file an EDF for software?

No. The AD bank can receive the EDF for software. STPI remains an option in the domestic tariff area.

What happens to my EDPMS entry after I file?

The bank enters it in EDPMS within five working days. It marks off the entry when the export value is realised, or when it allows a reduction.

How long do I have to realise payment for exported services?

Nine months from the invoice date, under regulation 5(1)(a) of the 2026 Regulations as amended on 22 September 2026. The limit is twelve months if the export is invoiced or settled in Indian rupees. Your AD bank may extend it on request.

Is the realisation period for services fifteen months?

No. The January 2026 text said fifteen months. FEMA 23(R)/(1)/2026-RB of 22 September 2026 cut it to nine months before the regulations came into force. The rupee period fell from eighteen to twelve months at the same time.

Can the AD bank extend the realisation period?

Yes. Under the second proviso to regulation 5, the AD bank may allow more time if the exporter asks and gives reasons the bank accepts. Ask before the nine month or twelve month limit passes.

Who can help us set up EDF filing?

Krystal7 Consultants sets up the monthly EDF routine with your bank and reconciles EDPMS each month. See our FEMA compliance service, or email [email protected] with a sample month of invoices.

Sources

Reserve Bank of India, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB, 13 January 2026, amended up to 22 September 2026, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13277
Reserve Bank of India, Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(1)/2026-RB, 22 September 2026, Gazette 24 September 2026, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13714
Reserve Bank of India, Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(8)/2026-RB, 5 June 2026, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13467
Reserve Bank of India, Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025, Notification No. FEMA 23(R)/(7)/2025-RB, 13 November 2025, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=12923
Reserve Bank of India, A.P. (DIR Series) Circular No. 20, Directions on Export and Import of Goods and Services, 16 January 2026, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13278&Mode=0
Reserve Bank of India, FEMA notifications list, read 1 October 2026, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx

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WRITTEN BY

CA Nandini

Co-founder · All India Rank 49, ICAI

CA Nandini is a co-founder of Krystal7. She leads brand, business development and marketing, and works with founders to define their engagement. She is a Chartered Accountant and achieved All India Rank 49 in the CA examinations.

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