Trade Policy
Service Export EDF Filing: 30-Day Rule | Trad
From 1 October 2026, IT, consulting and other service exporters must file an EDF within 30 days from month-end of invoice — one monthly EDF with an invoice-level schedule. Software cannot use the pay-on-receipt shortcut, and there is no small-invoice EDF exemption.
The 30-day rule in one paragraph
From 1 October 2026, every service and software export needs an Export Declaration Form (EDF) declaring the full export value. For services the deadline runs from invoicing, not delivery: file within 30 days from the end of the month in which the invoice was raised. October invoices mean filing within 30 days after end-October. This is the single biggest change for IT, consulting, and other service exporters, who previously had no prescribed declaration for non-software services.
General information, not legal advice
This is a practical guide to the FEMA 2026 EDF process, not legal advice. Your AD bank decides on your transaction, documents, and reasons. Confirm any transaction-specific position with your AD bank in writing before you act on it.
Where to file: DTA vs SEZ vs STPI
The filing counter depends on what you export and where you are located. Services expressly include software under the 2026 framework, but software has its own routing row.
| Exporter type | File EDF with | Notes |
|---|---|---|
| DTA, non-software services (IT services billed as services, consulting, professional services) | AD bank | Most common route for DTA service exporters |
| DTA, software | AD bank or STPI | Either counter works; STPI continues as specified authority for software EDFs |
| SEZ, services including software | Development Commissioner | SEZ route for both services and software |
| DTA goods for comparison | Customs (deemed via shipping bill at EDI ports) | Shown only for contrast; this post covers services |
Where the specified authority is not your AD bank (STPI or Development Commissioner), the authenticated EDF is forwarded to your AD bank, which must enter the service EDF in EDPMS within five working days of receipt.
One monthly EDF, invoice-level schedule
If you billed one or more recipients in a month, you may submit a single EDF covering all of that month's service exports. The single EDF is the declaration; the schedule behind it is what makes it auditable.
- Invoice number and date for every invoice in the month
- Service recipient name, address, and country
- Contract number and date, where applicable
- Currency and amount per invoice, plus net realisable value
- Description of services and SAC code per line (new vs the old SOFTEX dataset)
- Remarks linking credit notes, milestones, or advance adjustments
Keep the schedule at invoice level even though the EDF is monthly. Your AD bank closes EDPMS entries per invoice, and eBRC generation also maps remittances to invoices — a monthly total without invoice detail will not reconcile.
Pay-on-receipt option: non-software only
For services other than software, you may submit the EDF on or before the date of receipt of payment instead of waiting for the 30-day month-end deadline. This suits exporters paid quickly after invoicing.
Software is excluded from this option. A software exporter must follow the standard 30-day month-end route (or seek an extension). For partial payments against an invoice, confirm with your AD bank how the EDF and the EDPMS entry should reflect the part-receipt before you file.
Missed the deadline? The extension route
- Write to your AD bank citing reasons for the delay, invoice by invoice.
- The AD bank may extend the EDF submission period if it finds the reasons reasonable.
- Keep the written approval with the EDF record — an oral assurance does not close the compliance gap.
- If reasons are thin (repeated late filing with no cause), expect the bank to ask for process fixes before granting the next extension.
The Rs 10 lakh misconception — no small-invoice EDF exemption
There is no general small-invoice exemption from EDF reporting. A Rs 5 lakh consulting invoice and a Rs 50 lakh SaaS invoice both need EDF coverage.
The Rs 10 lakh relief is for EDPMS closure and reduction of export value per shipping bill or invoice — including bulk closure on quarterly declaration — not for skipping the EDF itself.
Concretely: the Rs 10 lakh per-invoice declaration route lets your AD bank close an EDPMS entry or permit a reduction (including full non-realisation) on your declaration. It does not remove the upstream duty to file the EDF declaring the full export value in the first place.
What to declare and what records to keep
Declare the full export value in the EDF — invoice USD 100,000 even if you expect USD 98,000 after an approved deduction. Adjustments, bank charges, discounts, and shortfalls are handled separately through the reduction process, not by under-declaring.
- Service invoices and underlying contracts or statements of work
- Delivery or performance evidence (timesheets, milestone acceptances, access logs as applicable)
- Receipt advices, IRMs, and eBRCs when proceeds arrive
- EDF copies with the invoice-level schedule
- Approved adjustments and AD bank correspondence, including extension approvals
Software exporters should note the definitional breadth: computer programs, databases, drawings, designs, audio and video signals, and information on non-physical media can all count as software. Borderline cases should be confirmed with the bank or specified authority before choosing the filing counter.
Keep reading
Service EDF questions before month-end?
Talk to trad — EDF filing, routing and extensions for service exporters.
Contact us →eBRC and FEMA 2026 for banks and exporters
How the EDF feeds EDPMS, IRM, and eBRC closure.
Read the eBRC guide →Frequently asked questions
What is the service export EDF due date under FEMA 2026?
Within 30 days from the end of the month in which the service invoice was raised. October 2026 invoices mean a deadline within 30 days after end-October (i.e. by end-November 2026). The rule comes from FEMA 23(R)/2026-RB Regulation 3(2), effective 1 October 2026.
Can one EDF cover multiple service invoices?
Yes. An exporter who billed one or more recipients in a month may submit a single monthly EDF for all those exports. Keep an invoice-level schedule (invoice no/date, buyer, country, currency, amount, SAC code, contract ref) behind the single EDF.
Can I file the service EDF on receipt of payment instead?
Only for non-software services: the regulation permits filing the EDF on or before the date of receipt of payment. This option is NOT available for software exports. For partial payments, confirm the treatment with your AD bank.
Where do I file the EDF — AD bank, STPI, or SEZ?
DTA non-software services: with your AD bank. DTA software: with your AD bank or STPI. SEZ (services and software): with the Development Commissioner. Where the specified authority is not the AD bank, the authenticated EDF is forwarded to your AD bank, which enters it in EDPMS within five working days.
Can the 30-day EDF deadline be extended?
Yes. The AD bank may extend the EDF submission period on a reasoned request it finds acceptable. Apply before the deadline where possible and keep the written approval on file.
Are small service invoices exempt from EDF?
No. There is no general small-invoice EDF exemption. The Rs 10 lakh relief is for EDPMS closure and reduction of export value per shipping bill or invoice — not for skipping EDF reporting. Every service invoice still needs EDF coverage.
What value do I declare in the EDF?
The full export value — e.g. invoice USD 100,000 even if you expect USD 98,000 after an approved deduction. Shortfalls and adjustments are handled separately through the reduction process with your AD bank, not by under-declaring the EDF.