RBI and FEMA

What have RBI and DGFT changed for service exporters since 2023?

Author:: Editorial team, serviceexportguide.com
Verified by:: Editorial team
Published: 28 October 2026
Last modified: 30 October 2026
Reading time: 9 min read

Short answer

From 1 October 2026 every service exporter files an Export Declaration Form under RBI's 2026 export regulations.¹ Services must be realised within nine months of the invoice date.¹² Exporters have self-certified e-BRCs since November 2023.³ Services e-BRCs carry a mode-of-export field from 1 May 2025.⁴ IEC bank accounts are validated through NPCI from February 2026.⁵

Applies to	Governed by	Deadline	Penalty	Last verified
Every exporter of services, from 1 October 2026	FEMA (Export and Import of Goods and Services) Regulations, 2026¹	EDF within 30 days from the end of the invoice month; realisation within nine months of the invoice date¹²	Banks may not charge penalties for a customer's regulatory delay¹	28 October 2026
Exporters generating services e-BRCs	DGFT Trade Notices 33/2023-24 and 02/2025-26³⁴	Mode of export field mandatory from 1 May 2025⁴	Not applicable	28 October 2026
IEC applicants and holders modifying an IEC	DGFT Trade Notice 23/2025-26⁵	NPCI validation from February 2026⁵	An application cannot be submitted while any account fails validation⁵	28 October 2026

Between November 2023 and October 2026, the Reserve Bank of India (RBI) and the Directorate General of Foreign Trade (DGFT) changed how Indian service exporters declare exports, prove realisation and keep their Importer Exporter Code (IEC) records.¹³ Many guides online still describe the old position.

This page lists only changes that affect service exporters and that we could trace to a dated RBI or DGFT document. Goods-only changes (customs, SIONs, quotas) are left out. For the Foreign Trade Policy alone, see FTP 2023 changes; for tax changes, see Budget 2026-27 changes.

What are the RBI and DGFT changes for service exporters?

The RBI and DGFT changes for service exporters are a new RBI export rulebook from 1 October 2026 and a self-certified e-BRC and validated IEC system at DGFT.¹³⁵

EDF for all: an Export Declaration Form (EDF) for every service export from 1 October 2026.¹
Realisation: nine months from the invoice date, or twelve months if invoiced or settled in rupees.¹²
e-BRCs: self-certified by exporters since Trade Notice 33/2023-24, with a mode-of-export field for services from 1 May 2025.³⁴
IEC: bank accounts validated through the National Payments Corporation of India (NPCI) from February 2026.⁵

The October 2026 rulebook is the change that touches every service exporter.¹

Who do the RBI and DGFT changes apply to?

The RBI changes apply to every exporter of services and to the AD banks that handle their money, and the DGFT changes apply to exporters who use e-BRCs, hold an IEC or claim Foreign Trade Policy (FTP) benefits.¹³⁵

Entity type	Applicable?	Why	Best for
Freelancer or agency exporting non-software services	Yes	Every service exporter files an EDF from 1 October 2026¹	Anyone who never filed a declaration before
Software or SaaS exporter	Yes	SOFTEX is replaced by the EDF for software¹	Former SOFTEX filers
Exporter using e-BRCs	Yes	e-BRCs are self-certified, with a mode-of-export field for services³⁴	GST-registered exporters claiming refunds
IEC applicant or holder	Yes	Bank accounts in IEC applications and modifications are validated through NPCI⁵	Exporters opening or editing an IEC
Exporter seeking status holder recognition	Yes	One Star Export House eligibility was eased on 21 August 2026⁷	Exporters with several years of exports

How each change applies depends on your bank, your payment routes and whether you claim FTP benefits.

How does a service exporter adjust to the 2026 RBI and DGFT changes?

A service exporter adjusts by filing an EDF for every export, keeping payment terms within nine months, self-certifying e-BRCs and keeping IEC bank details complete.¹³⁵

EDF: file an EDF for every service export within 30 days from the end of the invoice month; non-software services may file on or before the payment date.¹
Payment terms: set terms so each invoice is realised within nine months of its date, or twelve months if invoiced or settled in rupees.¹²
e-BRCs: generate e-BRCs on the DGFT portal from your bank's inward remittance messages, and select the mode of export for services.³⁴
IEC bank accounts: declare all active bank accounts linked to your PAN when you apply for or modify an IEC.⁵
AD bank approvals: go to your AD bank for extensions, reductions, set-offs and third-party receipts, which AD banks approve under the 2026 Regulations.¹

See what changed in the FEMA export regulations.

Which deadlines, limits and periods changed for service exporters?

The deadlines, limits and periods that changed are the EDF deadline, the realisation period, the cross-border aggregator cap, the small-entry closure limit and the repatriation period for accounts abroad.¹²¹³¹⁴¹²

Item	Current rule	Source date	Best for
EDF deadline	Within 30 days from the end of the invoice month; non-software services may file on or before the payment date	2026 Regulations, from 1 October 2026¹	Every service exporter
Realisation period	Nine months from the invoice date; twelve months if invoiced or settled in rupees	Amended 22 September 2026²	Setting payment terms
Cross-border aggregator cap	₹25 lakh per transaction	15 September 2025¹⁴	Exporters paid through a PA-CB
Small EDPMS entries	Closed on the exporter's declaration at ₹10 lakh or less	1 October 2025¹³	Small invoices with unmatched entries
Foreign currency account abroad	Use or repatriate by the end of the next month, or three months in an IFSC	14 January 2025 and 6 October 2025¹⁵¹²	Exporters holding earnings abroad

What happens if a service exporter misses the RBI and DGFT changes?

A service exporter who misses the changes may file no EDF where one is now required, set payment terms beyond the nine-month realisation period, or be unable to submit an IEC application.¹²⁵

No EDF: before 1 October 2026 non-software services needed no declaration; from that date every service export does.¹
Long payment terms: terms planned on the fifteen-month period of November 2025 run past the nine months that now apply.¹¹²
IEC blocked: an IEC application cannot be submitted while any declared bank account fails NPCI validation.⁵
Caution list: exporters on the caution list as at 30 September 2026 stay under their existing orders.²

The 2026 Regulations bar banks from charging penalties for a customer's regulatory delay.¹

What is the timeline of RBI and DGFT changes for service exporters?

The timeline runs from DGFT's self-certified e-BRC pilot in November 2023 to the RBI rulebook that took effect on 1 October 2026, newest first below.¹³

What did RBI change in October 2026?

1 October 2026: the 2026 Regulations and RBI Directions took effect. The FEMA (Export and Import of Goods and Services) Regulations, 2026 replaced the 2015 Regulations, and A.P. (DIR Series) Circular No. 20 of 16 January 2026 superseded the Master Directions on export and import.¹⁶ For service exporters this means:¹

EDF: an EDF for every service export, within 30 days from the end of the invoice month (non-software services may file on or before the payment date).¹
Software: SOFTEX is replaced by the EDF for software.¹
Realisation: within nine months from the invoice date, or twelve months if invoiced or settled in rupees.¹
Approvals: AD banks approve extensions, reductions, set-offs and third-party receipts without going to RBI.¹

What did RBI change in September 2026?

22 September 2026: RBI amended the 2026 Regulations before they took effect. Notification FEMA 23(R)/(1)/2026-RB replaced "fifteen months" with "nine months" and "eighteen months" with "twelve months" in regulation 5, kept exporters on the caution list as at 30 September 2026 under their existing orders, and added regulation 20 letting AD banks handle pre-October 2026 transactions that used to need RBI approval.²

What did DGFT change in August 2026?

21 August 2026, One Star Export House: DGFT Notification No. 33/2026-27 amended para 1.25(d) of the FTP 2023 so that One Star Export House status (outside gems and jewellery) needs export performance in any two of the three preceding financial years, where all three were needed before.⁷ Status holder recognition is open to exporters of goods, services and technology. See DGFT status holder.
20 August 2026, rupee and foreign currency receipts: DGFT Notification No. 30/2026-27 rewrote FTP paras 2.52 and 2.53: export contracts and invoices (other than those involving Asian Clearing Union members) may be denominated in foreign currency or rupees, proceeds may be realised in any foreign currency or rupees, and rupee proceeds credited to accounts of persons resident outside India qualify for FTP benefits on par with foreign currency.⁸

What did RBI change in June 2026?

5 June 2026: realisation period back to nine months. Notification FEMA 23(R)/(8)/2026-RB amended regulation 9 of the 2015 Regulations, replacing "fifteen months" with "nine months", from its publication in the Official Gazette.⁹

What did DGFT and RBI change in January and February 2026?

6 February 2026, NPCI validation of IEC bank accounts: DGFT Trade Notice 23/2025-26 says that from February 2026 bank accounts given in IEC applications and modifications are validated in real time through NPCI. Applicants must declare all active bank accounts linked to their PAN, and an application cannot be submitted while any account fails validation.⁵
13 to 16 January 2026, new RBI rulebook notified: RBI notified the 2026 Regulations (FEMA 23(R)/2026-RB dated 13 January 2026) and issued Circular No. 20 on 16 January 2026, both effective from 1 October 2026.¹⁶

What did RBI and DGFT change in late 2025?

20 November 2025, online IEC validation: DGFT Public Notice 32/2025-26 merged form ANF-1A into ANF-2A and amended para 2.08 of the Handbook of Procedures so IEC application details are validated through online integration with government and bank records.¹⁰ See how to apply for an IEC.
13 November 2025, fifteen months: Notification FEMA 23(R)/(7)/2025-RB replaced "nine months" with "fifteen months" in regulation 9 of the 2015 Regulations, from its publication in the Official Gazette.¹¹
6 October 2025, IFSC accounts: FEMA 10(R)(7)/2025-RB allowed exporters' foreign currency accounts abroad to be held in an International Financial Services Centre, with funds to be used or repatriated within three months there (end of next month elsewhere).¹²
1 October 2025, small entries: A.P. (DIR Series) Circular No. 12 told banks to close EDPMS entries of ₹10 lakh or less on the exporter's declaration and not to levy penal charges for delays.¹³
15 September 2025, payment aggregators: RBI's Master Direction on Regulation of Payment Aggregator set a ₹25 lakh per-transaction cap for cross-border aggregators and required them to give exporters' banks documents for EDPMS closure.¹⁴

What did RBI and DGFT change earlier in 2025?

21 April 2025 (effective 1 May 2025), mode of export in e-BRCs: DGFT Trade Notice 02/2025-26 made "Mode of Export of Services" a mandatory field for services e-BRCs, using the four WTO GATS modes.⁴ See e-BRC on DGFT.
10 February 2025, ACU receipts: FEMA 14(R)(1)/2025-RB amended the Manner of Receipt and Payment Regulations so that only payments between participants in Asian Clearing Union countries must use the ACU mechanism; other transactions follow the general rule.¹⁶
14 January 2025, foreign currency accounts abroad: FEMA 10(R)(5)/2025-RB inserted regulation 5(CA), allowing an exporter to hold a foreign currency account with a bank outside India for export receipts, with funds to be used for imports or repatriated by the end of the next month.¹⁵

What did DGFT change in 2023 and 2024?

14 August 2024 (effective 20 August 2024), bulk and API e-BRCs: DGFT Trade Notice 12/2024-25 added bulk upload and API integration for e-BRC self-certification.¹⁷
10 November 2023 (pilot from 15 November 2023), self-certified e-BRCs: DGFT Trade Notice 33/2023-24 moved e-BRCs to a system where banks send Inward Remittance Messages to DGFT and exporters self-certify, with banks required to integrate by API by 31 January 2024.³ See BRC vs e-BRC.

What are the common mistakes with the RBI and DGFT changes?

The common mistakes are relying on guides written before October 2026, using an outdated realisation period, and treating the e-BRC as something the bank issues.¹²³

Old guides: following guides that describe SOFTEX or the Master Direction for exports from 1 October 2026.¹⁶
Fifteen months: using the fifteen-month realisation period, which was reversed in June 2026 and is not in the 2026 Regulations as amended.⁹²
Waiting for the bank: expecting the bank to issue e-BRCs, which exporters self-certify on the DGFT portal.³
Incomplete IEC accounts: leaving an active PAN-linked bank account out of an IEC modification.⁵

How each change applies to your business depends on your bank, your payment routes and whether you claim FTP benefits, so confirm with your bank or a chartered accountant.¹

How did we verify this?

We checked this page against the sources below on 30 October 2026. Read our methodology or report an error.

Frequently asked questions

What is the single most important change for freelancers?+

The most important change for freelancers is the Export Declaration Form. From 1 October 2026, every exporter of services must file an EDF with the specified authority, usually the AD bank, within 30 days from the end of the invoice month.¹ Before that date, exporters of non-software services needed no declaration.

Why did the realisation period change so many times?+

RBI extended the realisation period to fifteen months in November 2025, returned it to nine months in June 2026, and on 22 September 2026 amended the 2026 Regulations so they also start at nine months from the invoice date.¹¹⁹² RBI's notifications do not give reasons for the changes.

Do I need to do anything about the e-BRC changes?+

If you use e-BRCs, you generate them yourself on the DGFT portal from your bank's inward remittance messages, under the system introduced by DGFT Trade Notice 33/2023-24.³ For services e-BRCs, select the mode of export, a mandatory field from 1 May 2025 under Trade Notice 02/2025-26.⁴

Did any of the RBI and DGFT changes add fees?+

The 2026 Regulations require bank charges to be reasonable and proportional and bar banks from charging penalties for a customer's regulatory delay.¹ DGFT's e-BRC trade notices do not mention a fee for self-certification of e-BRCs by exporters.³ Check your own bank's published schedule of charges.

Can exporters now invoice foreign clients in rupees under the FTP?+

Yes. DGFT Notification No. 30/2026-27 of 20 August 2026 says export contracts and invoices, other than those involving Asian Clearing Union members, may be denominated in foreign currency or rupees.⁸ Rupee proceeds credited to accounts of persons resident outside India qualify for FTP benefits on par with foreign currency.⁸

Can an exporter keep export earnings in a foreign bank account?+

An exporter can hold a foreign currency account with a bank outside India for export receipts under regulation 5(CA), inserted in January 2025.¹⁵ Funds must be used for imports or repatriated by the end of the next month, or within three months for an account in an International Financial Services Centre.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.

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