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RBI and FEMA

When is the EDF due for a service invoice?

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Short answer

The Export Declaration Form (EDF) for exported services is due within 30 days from the end of the month in which the invoice was raised, under regulation 3(2) of the FEMA (Export and Import of Goods and Services) Regulations, 2026.1 An exporter of services other than software may instead file it on or before the date payment is received, and the bank can extend the deadline on a reasoned request.1

The Export Declaration Form (EDF) deadline for a service export is fixed by the end of the month in which you raised the invoice, not by the invoice date itself. From 1 October 2026, regulation 3(2) of the FEMA (Export and Import of Goods and Services) Regulations, 2026 (the 2026 Regulations) gives 30 days from the end of that month.1

What are the deadlines for sample invoice dates?

The table applies the 30-day rule to invoices raised by different exporters.1

Exporter and invoice dateMonth endsEDF due by
Video editor, 4 November 202630 November 202630 December 2026
Marketing agency, 28 November 202630 November 202630 December 2026
Developer, 15 December 202631 December 202630 January 2027
Tutor, 2 February 202728 February 202730 March 2027

Every invoice in the same month shares one deadline, because regulation 3(2)(a) allows a single EDF for all services exported in a month.1

When can you file on the payment date instead?

An exporter of services other than software may submit the EDF on or before the date payment is received, under regulation 3(2)(b).1 A management consultant invoicing on 5 November 2026 on 90-day terms could therefore file when the money arrives in February 2027, rather than by 30 December 2026.

The catch is the definition of software. Regulation 2(1)(e) covers "any computer programme, database, drawing, design, audio/video signals" and other information delivered other than on a physical medium.1 That can include design files and edited video, so ask your bank which category it puts you in before relying on the later date. The EDF guide explains how the definition lines up with common work.

What if you cannot meet the deadline?

Ask your Authorised Dealer (AD) bank for more time. Regulation 3(2)(c) lets the bank extend the period on your request citing reasons for the delay.1 Regulation 19(3) bars the bank from levying any charge or penalty on you for a regulatory delay on your part, though it can charge reasonable fees for its services.1

Is the EDF deadline the same as the payment deadline?

No. The EDF deadline is about declaring the export. The realisation deadline is about receiving the money: nine months from the invoice date for services, or twelve months if invoiced or settled in Indian rupees.12 See the export realisation period guide.

Your bank's own procedure sets the filing channel and documents, so check it, and ask a chartered accountant if your work could fall on either side of the software line.

How did we verify this?

We checked this page against the sources below on 28 October 2026. Read our methodology or report an error.

  1. [1]RBI: Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB, amended up to 22 September 2026 (regulations 2, 3 and 5)
  2. [2]RBI: FEMA (Export and Import of Goods and Services) (Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(1)/2026-RB dated 22 September 2026

Frequently asked questions

Does the EDF deadline run from the invoice date or the payment date?+

The default deadline runs from the end of the invoice month: 30 days after it.1 Only exporters of non-software services can use the payment date instead.

Can a software developer file the EDF when the client pays?+

No. The payment-date option in regulation 3(2)(b) is for services other than software, so a software exporter uses the 30-day rule.1

Does filing the EDF late change my realisation deadline?+

No. The nine-month realisation period runs from the invoice date whether or not the EDF has been filed.12

This page is general information for Indian service exporters, not tax or legal advice. Rules change and outcomes depend on your facts, so confirm with a chartered accountant before acting.