From 1 October 2026, an Indian business exporting services must file an Export Declaration Form (EDF) for its export invoices. This is required by Regulation 3(2) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. For services other than software, the EDF goes to the authorised dealer bank, or, for an SEZ unit, to the Development Commissioner. It is due within 30 days after the end of the month in which the invoice was raised, or, for services other than software, on or before the date payment is received. One EDF can cover the whole month. The bank records it in the Export Data Processing and Monitoring System (EDPMS) and closes each entry as payment arrives. The new risk is not the filing itself. It is three records of the same exports, in the EDF, in GSTR-1 and in the books, drifting apart. This post covers the rules and a monthly routine that keeps them aligned.
What the regulation requires
Under Regulation 3(2) of the 2026 regulations:
- What: an EDF stating the full export value of the services exported.
- When: within 30 days after the end of the month in which the invoice was raised.
- Consolidation: one EDF may cover all services exported to one or more recipients in a month.
- Alternative timing for services other than software: the EDF may instead be filed on or before the date payment is received.
- Extension: the authorised dealer may extend the time on the exporter's request, if satisfied with the reasons.
Where it is filed depends on the service and the exporter's location, under Regulation 2(1)(f). Services other than software are filed with an authorised dealer bank in the domestic tariff area, or with the Development Commissioner for an SEZ unit. For software, the authorised dealer or STPI in the domestic tariff area, or the Development Commissioner in an SEZ.
What the bank does with it. Under Regulation 18(1)(b), the authorised dealer must enter the EDF details in EDPMS within five working days of receiving it. When export proceeds are credited, the bank updates or closes the entry. Under the proviso to Regulation 4(2), for invoices up to ₹10 lakh, the entry may be closed on the exporter's declaration that payment has been realised, in full or otherwise, and such declarations may be given quarterly in bulk.
Why this is a new task for service exporters
Under the 2015 export regulations, the declaration requirement in Regulation 3(1) covered goods and software. Regulation 3(3) allowed other services to be exported without furnishing any declaration, although the export value still had to be realised and repatriated. From 1 October 2026, export invoices need an EDF, filed either within 30 days after the month-end or, for services other than software, on or before the date payment is received. For a service exporter, that means a regular filing routine with the bank, alongside the monthly or quarterly GST returns.
Under Regulation 19, each authorised dealer must have a documented internal policy and standard operating procedure for handling export transactions, and must disclose the policy and the main features of the procedure on its website. Read your bank's version before the first filing.
Three records of the same exports
From October 2026, each export invoice appears in three places:
- The books: the sales invoice, in foreign currency and in rupees, and later the receipt against it.
- GSTR-1: the invoice reported as an export, with or without payment of IGST.
- The EDF and EDPMS: the invoice declared to the bank, later closed against the remittance.
Where they are prepared at different times by different people, such as the accounts team, a tax consultant and whoever deals with the bank, differences can creep in: an invoice in GSTR-1 but missing from the EDF, a different exchange rate, a credit note in one record but not the others. Each difference can become a question later, from the bank when an entry stays open, or from a GST officer reviewing a refund claim.
A monthly routine that keeps them in agreement
Run this after each month-end, once the month's invoices are final.
- Freeze the month's export invoice list from the books: invoice number, date, client, country, currency, amount and the nature of the service.
- Prepare GSTR-1 from that list, so that the export invoices reported match it exactly.
- Prepare the EDF from the same list, within 30 days of month-end, or by each payment date if you use that option for services other than software, so the bank receives the same invoice numbers and values.
- Reconcile the three. The count and total of export invoices should agree across the books, GSTR-1 and the EDF. Record any credit notes or amendments in all three.
- Match receipts as they arrive. Apply each remittance to its invoices in the books. Make sure the bank knows which EDF entries the remittance closes, and keep the remittance advice or FIRC and e-BRC with the invoice.
- Review open entries. Monthly, list EDF entries not yet closed by realisation. Compare each with the realisation deadline: nine months from the invoice date, or twelve for rupee invoices. Ask the bank for an extension or reduction early where needed.
A single invoice register that feeds all three records is the simplest control. Retyping the same data into three formats is where differences start.
Points to watch
- Advance receipts. Where a client pays before the invoice, record the advance in the books against the client. When the invoice is raised, tell the bank which invoice and EDF the advance relates to.
- Credit notes and partial payments. A reduced invoice value needs to be reflected in the books, in GST reporting and with the bank. For a shortfall, the bank may allow a reduction in realisation under Regulation 6, on the exporter's request. For invoices up to ₹10 lakh, the reduction may be permitted on the exporter's declaration.
- Payments through platforms. Consolidated payouts from payment platforms must be broken down to invoices, so the bank can close the right EDF entries.
- Software exports. In the domestic tariff area, the EDF for software may be filed with the bank or with STPI. Where STPI is the specified authority, Regulation 3(3) requires it to forward the authenticated EDF to the bank.
- Invoices raised before 1 October 2026. The EDF requirement applies under the 2026 regulations. For older open invoices, confirm with the bank how they are being monitored.
Where this fits
The EDF is now the first step in the export receipt trail. The rest is covered in FIRC and e-BRC: the paper trail your service exports need, and the deadline it is measured against in Export realisation is nine months again.
Wissen Solutions prepares monthly export invoice registers that feed GSTR-1 and the EDF, and reconciles them each month, through our GST, income tax and TDS return filing services.
Sources (checked 26 October 2026)
- RBI: Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB, as amended: Regulations 2(1)(f), 3(2), 3(3), 4(2), 6, 18(1)(b) and 19
- RBI: Foreign Exchange Management (Export of Goods & Services) Regulations, 2015, Notification No. FEMA 23(R)/2015-RB: Regulation 3