*Written by CA Nandini, Krystal7 Consultants. Last updated 24 September 2026.*
**The Export Declaration Form (EDF) is the form an Indian exporter uses to declare the full value of an export under FEMA. From 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 rule comes from RBI notification FEMA 23(R)/2026-RB dated 13 January 2026.**
Until now, 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 change that from 1 October 2026. This guide answers the questions we hear most from founders and finance teams.
## 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 RBI has not prescribed 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 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.
1. **Confirm the category.** Check whether each invoice is for goods, software or other services. This decides the authority and the timing.
2. **Keep an export invoice register.** Record invoice number, date, client name and country, currency, amount and a short description of the service.
3. **Close the month.** On the first working day of the next month, lock the list of export invoices raised in the month just ended.
4. **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.
5. **Sign and submit.** File it with the AD bank, or with STPI for software, within 30 days after the month end.
6. **Get the acknowledgement.** Keep the bank's receipt. Under regulation 18, the bank enters service EDFs in EDPMS within five working days of receipt.
7. **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.
8. **Review open entries.** Each month, list invoices still unpaid and their 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](/insights/gst-on-export-of-services-from-india).
## 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 | 15 months from the date of shipment | 15 months from the invoice date |
| Rupee invoicing | 18 months | 18 months |
The realisation periods come from regulation 5. They apply to exports made from 1 October 2026.
## 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:
1. File the late EDF at once and ask the bank to extend the time under regulation 3(2)(c), with your reasons.
2. If the bank refuses, or the gap is large, look at compounding with the RBI. Our [FEMA compounding guide](/insights/fema-compounding-application-a-complete-guide-to-resolving-fema-contraventions-in-2026) 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 15 months 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.
## 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](/insights/softex-form-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 |
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, from 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.
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](/services/fema-compliances.html), or email [email protected] with a sample month of invoices.
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