IT and consulting firms face new 30-day EDF filing deadline for service exports under FEMA rules

IT companies, consulting firms and other service exporters must comply with a new declaration requirement under the Reserve Bank of India’s revised foreign exchange framework, which came into effect on October 1, 2026. Exporters must file an Export Declaration Form (EDF) within 30 days from the end of the month in which an invoice is raised, with an earlier deadline if payment is received before then.

The revised Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, consolidate rules governing cross-border transactions and expand the role of authorised dealer (AD) banks in handling export and import compliance.

According to a newsflash issued by RSM India on October 14, the EDF requirement has been extended to exports of services, making timely coordination between billing, treasury and compliance teams important for service providers.

Monthly consolidated filing permitted

Service exporters are not required to file a separate EDF for every invoice. A single declaration can cover multiple invoices raised during a month, including invoices issued to different overseas customers.

However, exporters must provide invoice-wise information, including the customer’s name, country, invoice number and date, currency, invoice value and nature of services.

For example, invoices raised during October 2026 may be covered in a consolidated EDF filed by November 30. If payment is received before the normal filing deadline, the declaration must be submitted on or before the date of receipt.

This means companies will need processes to track invoice dates and incoming payments to avoid missing the applicable deadline.

Software exporters must check procedures

Software continues to be treated as a service under the revised framework. The existing SOFTEX process is expected to continue where applicable, but the filing procedure may vary depending on the exporter’s location and the relevant authority.

Exporters operating in the Domestic Tariff Area may need to submit declarations through their AD bank or the Software Technology Parks of India (STPI), while exporters in special economic zones may deal with the Development Commissioner, as applicable.

RSM India has advised software exporters to check the revised procedure with their respective bank or relevant authority.

Export realisation deadline also revised

The framework also requires export proceeds to be realised and repatriated within nine months from shipment for goods and from the invoice date for services, including software exports. Exports invoiced or settled in Indian rupees have a 12-month period.

Exporters unable to realise proceeds within the prescribed timeline may approach their AD bank for an extension, supported by reasons and relevant documents.

Businesses should update their compliance calendars, align billing and treasury teams, and obtain revised procedures and document checklists from their AD banks to manage the new requirements.