Starting October 1, 2026, the RBI has made it mandatory for every Indian service and software exporter to submit an Export Declaration Form (EDF) for cross-border income.
This was previously enforced primarily for physical goods. With the new rollout, however, the regulation now applies to all digital services, SaaS providers, software exporters, and freelancers who receive international remittances.
Table of Contents
What Has Changed?
Under updated FEMA guidelines, AD Category-I banks are required to log all international service export transactions on the RBI’s Export Data Processing and Monitoring System (EDPMS) portal.
To initiate this process, exporters must submit an Export Declaration Form for every invoice raised on or after October 1, 2026. Without this submission, banks cannot map incoming funds against your export invoices, which may cause delays in payment reconciliation or eBRC issuance.
Who Needs to Comply?
This rule applies to all Indian entities and individuals exporting services or software outside India, including:
- IT services firms, agencies, and consultancies
- Software exporters and SaaS businesses
- Independent freelancers receiving international client payments
Steps Exporters Need to Take
Step 1: File the Export Declaration Form
Submit the export declaration form to the Authorised Dealer (AD) bank where your foreign export proceeds are received. You can file an individual form per invoice or submit a single consolidated EDF covering all service invoices raised during a calendar month.
- Filing Deadline: Within 30 days from the end of the month in which the invoice was issued, or on/before the date the foreign remittance is received.
Step 2: Provide Proof of Remittance
Once the bank logs your EDF entry into the EDPMS portal, the payment received must be matched against the declared invoice value using your Foreign Inward Remittance Advice (FIRA/FIRC).
- For invoices up to ₹10 Lakh (or equivalent): Banks typically require a simple self-declaration confirming receipt of payment against the specific invoice(s).
- For invoices above ₹10 Lakh: You must submit the underlying invoice, proof of payment (FIRA), and matching instructions to your bank.
Step 3: Complete EDPMS Reconciliation & Obtain eBRC
Once your AD bank successfully pairs the EDF entry with your inward remittance, they will close the EDPMS record. The Director General of Foreign Trade (DGFT) system then generates an electronic Bank Realisation Certificate (eBRC), bringing your export transaction into full regulatory compliance.
Clarification on AD Bank Identification and EDF Filing for INR Settlements
1. Who acts as the AD Bank?
- MX’s AD Bank is its own corporate banking partner. This is the Authorised Dealer (AD Category-I) Bank where MX holds its primary business account and has registered its Import Export Code (IEC) / AD Code.
- International card payments are processed and routed through Razorpay’s cross-border bank partners. Even so, MX must file its master EDF declaration with its own current account bank, which receives the final settlements.
2. How will MX file the EDF when settlement is received in INR?
- Invoice-based reporting: The EDF is filed based on the underlying export invoices issued to foreign customers during the month. This applies whether the invoice is billed in FCY or INR.
- Monthly consolidated filing: MX will include all international card sales in its monthly consolidated EDF submission to its AD Bank, within 30 days of the month-end.
- Reconciliation via FIRS: Funds are settled in INR via Razorpay. MX will therefore share the Foreign Inward Remittance Statement (FIRS) / NOC provided by Razorpay, or available on its Razorpay Dashboard, with its AD Bank. The AD Bank will map these INR credits against the EDF invoices to update EDPMS and issue the eBRC.
Suggested Next Steps
To stay ahead of these regulatory updates and ensure your international payouts remain seamless, we suggest taking the following steps:
-
Reach Out to Your AD Bank: Contact your primary corporate banking partner as soon as possible to confirm their specific submission process, required documentation, and month-end filing workflow for service exports.
-
Review Detailed Guidelines: For full regulatory context, procedural rules, and official references, please review the complete RBI Guidelines on EDF Compliance.
If you need further guidance, please contact us.
