EDF for Export of Services Up to Rs 10 Lakh: RBI’s Second Amendment Deems Filing and Narrows IDPMS Reporting for Service Imports
Quick Summary
- What is new: RBI Notification No. FEMA 23(R)/(2)/2026-RB dated 2 November 2026, the Foreign Exchange Management (Export and Import of Goods and Services) (Second Amendment) Regulations, 2026, published in the Gazette the same day. It comes into force from 1 October 2026, the date the principal Regulations commenced.
- Resident individuals exporting services: the EDF is deemed submitted when the exporter gives the Authorised Dealer the information required for the receipt of payment, for crediting the exporter’s account.
- Companies, LLPs and other non-individuals: the same deeming applies only if the value of the inward remittance for the service is not more than Rs 10 lakh (or its foreign currency equivalent).
- Service imports: the AD bank’s IDPMS entry under regulation 18(1)(d) now covers only importers other than resident individuals, where the invoice or contract value is more than Rs 10 lakh.
- Not changed: the realisation periods in regulation 5, and the EDF for service exports outside the two deeming provisos.
The EDF for export of services has a new carve-out. RBI’s Second Amendment of 2 November 2026 treats the Export Declaration Form as submitted in two defined cases, and narrows the reporting of service imports in IDPMS. It changes three provisions only: regulations 2(1), 3(2) and 18(1)(d) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. This note is for freelancers, IT and SaaS exporters, founders who pay for overseas services, and the CAs who handle their AD bank paperwork. It builds on our note on the realisation period from 1 October 2026.
What did the EDF for export of services require before the amendment?
Regulation 3(2) requires an exporter of services to furnish to the specified authority a declaration in the EDF showing the full export value of services, within 30 days from the end of the month in which the invoice is raised. That main rule stays. The amendment adds two deeming provisos before the existing ones.
When is the EDF deemed submitted from 1 October 2026?
| Exporter of services | Condition | Result |
|---|---|---|
| Resident individual (new regulation 2(1)(da): a person resident in India who is a natural person) | Provides the information required in relation to the receipt of payment to the AD, for crediting the exporter’s account | EDF deemed submitted (proviso (a)). The proviso carries no value limit. |
| Person other than a resident individual | Same, and the value of the inward remittance for the service is not more than Rs 10 lakh or its foreign currency equivalent | EDF deemed submitted (proviso (b)) |
| Person other than a resident individual, inward remittance above Rs 10 lakh | Proviso (b) is not met | EDF under the main rule: within 30 days from the end of the invoice month |
A company, LLP or partnership firm is not a natural person, so it falls under proviso (b). The earlier provisos are renumbered (c), (d) and (e) and otherwise stand: a single EDF may cover all exports in a month; an exporter of services other than software may submit the EDF on or before the date of receipt of payment; and the AD may extend the time on a reasoned request.
The test in proviso (b) is the value of the inward remittance, not the invoice or the month’s billing. The EDF for a company has not been abolished; it is treated as filed only where the remittance is within the limit and the information has been given to the AD. Regulation 2(1)(f) names the Development Commissioner as the specified authority in a SEZ, and an AD or STPI for software in the DTA. The new provisos speak of information given to the AD.
What changes for import of services in IDPMS?
Regulation 18(1)(d) earlier required the AD to enter details of import of service in IDPMS “as declared and submitted by the importer, within five working days of receipt of documents”. It now reads:
“shall enter details of import of service in IDPMS, as furnished by the importer who is a person other than a resident individual and where the invoice or the contract value is more than ₹10 Lakh (or its equivalent in foreign currency), within five working days of receipt of details”
So a resident individual importer of services falls outside this clause, as does any importer where the invoice or contract value is Rs 10 lakh or less. Regulation 18(1)(e) is untouched: the AD still enters details of inward and outward remittances for all exports and imports in EDPMS or IDPMS.
Which Rs 10 lakh test applies where?
The Regulations now use the same figure with different yardsticks. Mapping a transaction to the wrong one is the easiest mistake to make here.
| Provision | Measured on | Effect |
|---|---|---|
| Regulation 3(2), proviso (b) | Value of the inward remittance for the service | EDF deemed submitted, up to Rs 10 lakh (non-individuals) |
| Regulation 18(1)(d) | Invoice or contract value | AD enters import of service in IDPMS, above Rs 10 lakh (non-individuals) |
| Regulation 4(2), first proviso | Invoice (services) or shipping bill (goods) | EDPMS entry may be closed on the exporter’s declaration, up to Rs 10 lakh, or quarterly in bulk |
| Regulation 4(2), second proviso | Invoice (services) or Bill of Entry (goods) | IDPMS entry may be closed on the importer’s declaration, up to Rs 10 lakh, or quarterly in bulk |
| Regulation 6, proviso | Invoice (services) or shipping bill (goods) | Reduction in export value on the exporter’s declaration, up to Rs 10 lakh |
Only the first two rows come from this amendment. A company with a Rs 12 lakh invoice paid through a single remittance of Rs 12 lakh is outside all three export-side relaxations in this table.
What has not changed?
- Realisation: regulation 5 is untouched. Services stay at nine months from the date of invoice, and twelve months where invoiced or settled in Indian Rupees.
- Goods: the EDF for goods under regulation 3(1) is untouched.
- AD monitoring: regulation 18(1)(f) still requires the AD to monitor EDPMS and IDPMS for closure of outstanding entries and to follow up for documents.
- AD diligence: regulation 4(2) still requires the AD to be satisfied of the genuineness of the transaction before crediting or debiting the account.
What should exporters, importers and their CAs do now?
- Classify the entity. Record whether the exporter or importer is a resident individual or a person other than one.
- Track remittance value for service exports. For a non-individual, add the inward remittance value to your EDF tracker alongside the invoice value.
- Keep the EDF calendar running. For invoices raised in October 2026 under the main rule, the 30 days from the end of the month end on 30 November 2026.
- Speak to your AD bank where payment follows the invoice. The deeming provisos are tied to the receipt of payment, while the 30-day period runs from the invoice month. Confirm how your bank is handling invoices that are unpaid when that period ends, and part payments of a larger invoice.
- Review open service import details. For non-individuals, identify invoices or contracts above Rs 10 lakh and furnish details to the AD. Keep the regulation 4(2) declaration route in mind for invoices up to Rs 10 lakh.
If an EDF slips, regulation 3(2)(e) lets you ask the AD for more time with reasons. Exporters who hedge these receivables should also read our note on the RBI forex hedging rules of October 2026.
Sources
- Source: Reserve Bank of India, Notification No. FEMA 23(R)/(2)/2026-RB dated 2 November 2026, Foreign Exchange Management (Export and Import of Goods and Services) (Second Amendment) Regulations, 2026, published in the Gazette of India, Extraordinary, Part III, Section 4 on 2 November 2026, rbi.org.in.
- Source: Reserve Bank of India, Notification No. FEMA 23(R)/2026-RB dated 13 January 2026, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (amended up to 2 November 2026), rbi.org.in.
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Disclaimer: This article is for general information only and reflects the RBI instruments cited above as on 6 November 2026. It is not legal advice. Please consult a qualified professional before acting on it.
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