Canonical summary. Primary research and the full source list are in research/01-rbi-fema-edf.md.
Last reviewed: 2026-10-03. Change log at the bottom.
1. Legal instruments
| Instrument | Key facts | Status |
|---|---|---|
| FEMA 23(R)/2026-RB, 13 Jan 2026: FEM (Export and Import of Goods and Services) Regulations, 2026 | In force 1 Oct 2026 (Reg. 1(2)). Supersedes FEMA 23(R)/2015-RB, but things done before supersession are saved. Gazette CG-MH-E-15012026-269352. | VERIFIED |
| FEMA 23(R)/(1)/2026-RB, 22 Sept 2026 (Gazette 24 Sept 2026) | Reg. 5(1): realisation period changed from 15 months to 9 months, and the INR proviso from 18 months to 12 months. Old Caution List orders continue (Reg. 13 proviso). New Reg. 20 lets AD banks handle pre-Oct cases. | VERIFIED (read on rbi.org.in, Id=13714) |
| A.P. (DIR Series) Circular No. 20, RBI/2025-26/194, 16 Jan 2026 | From 1 Oct 2026, Master Direction – Export of Goods & Services and Master Direction – Import are superseded, along with all listed circulars (including every SOFTEX circular). | VERIFIED |
| RBI Master Direction on Payment Aggregators, RBI/DPSS/2025-26/141, 15 Sept 2025, para 11 | PA-CB per-transaction cap ₹25 lakh. Under para 11(h) the PA-CB must give “the AD bank of the exporter” the documents it needs to close the EDPMS entry. | VERIFIED |
| FEM (Manner of Receipt and Payment) Regulations, 2023 (FEMA 14(R)/2023-RB) | How export proceeds may be received (Reg. 4(1) of the 2026 regs points to it). | VERIFIED (exists); details not re-read |
| RBI FAQ on the 2026 regs | None published as of 3 Oct 2026 | VERIFIED (absence) |
2. Core obligation (Reg. 3(2), VERIFIED)
An exporter of services shall furnish to the specified authority a declaration in EDF specifying the amount representing the full export value of services, within 30 days from the end of month in which invoice for services has been raised.
- (a) Consolidation: an exporter who served one or more recipients in a month may submit one EDF for all of that month’s exports.
- (b) Early option: exporters of services other than software may submit the EDF on or before the date payment is received.
- (c) Extension: the AD may extend the period on the exporter’s request, “citing reasons for delay”.
- “Services” includes “software” (Explanation to Reg. 2). “Software” means “any computer programme, database, drawing, design, audio/video signals, any information by whatever name called in or on any medium other than in or on any physical medium.”
Specified authority (Reg. 3(3), VERIFIED)
| Export type | Unit in a domestic tariff area (DTA), i.e. nearly every freelancer | SEZ unit |
|---|---|---|
| Services other than software | Authorised Dealer (AD) bank | Development Commissioner, SEZ |
| Software | AD bank or STPI | Development Commissioner, SEZ |
Who it applies to
- Every exporter of services, individuals included. There is no value threshold and no exemption for individuals or small exporters (VERIFIED: no such carve-out appears anywhere in the text). Secondary sources unanimously agree that freelancers are covered.
- The exporter files. Payment aggregators and platforms do not file on the exporter’s behalf. There is no provision for it, and Skydo, Razorpay and Xflow publicly confirm they don’t (REPORTED).
- The AD must enter a services EDF into EDPMS within 5 working days of receiving it (Reg. 18(1)(b)) (VERIFIED).
3. The form
There is one form for goods and services, set out in the Annex to the regulations. Axis Bank publishes the same form as “Annexure 6” (VERIFIED). The machine-readable field map is in priv/reference_data/edf_fields.json.
Part 1 — General information
| Field | Freelancer value / source in easylancing |
|---|---|
| Type of export |
Service |
| Form No. | Bank-assigned or blank (see §6); we never invent one |
| Shipping Bill No. & Date | N/A (goods only) |
| Mode of Transport/Delivery |
Internet |
| Category of Exporter |
Options on the form: Custom (DTA units) · SEZ · 100% EOU · Warehouse export · others (Specify). Default: others, specified as “Service exporter”. UNCERTAIN: some banks may expect “Custom (DTA units)”. The user picks, with a hint. |
| AD code; AD Name & Address | From the user’s selected bank account. The user obtains the AD code from their bank. Format UNCERTAIN: secondary sources disagree (commonly described as 14 digits; some say 7), so the product does not validate its format |
| IE Code | User’s IEC, if they have one. UNCERTAIN whether banks accept PAN in its place (IEC is not legally required for services; FTP ¶2.05(a)). |
| GSTIN | If registered |
| PAN | Required |
| Exporter’s Name & Address | Profile |
| Mode of Realisation |
Usually Others (the form text covers “advance payment, etc. including transfer/remittance to bank a/c maintained overseas”). L/C or BG is rare for freelancers. |
| Consignee Name & Address | For a single-client month: the client. For several clients: “As per Part 2B”. UNCERTAIN, bank-specific. |
| Port of Loading / Discharge, Date of LEO | N/A |
| Third Party name & Address; Relationship | Fill in when the payer is not the client, e.g. Deel, Upwork, Remote. Relationship example: “Payment platform / Employer-of-Record engaged by the service recipient”. See §7. |
| Country of Final Destination | Client country. For multiple clients: “As per Part 2B”. |
| Description of Goods/Services | Short summary, e.g. “Software development and IT consulting services” |
| Total FOB/Services value in words (INR) | Sum of Part 2B, converted to INR (see §5) |
Part 2B — Export value of services (one row per recipient and invoice)
| Column | Source |
|---|---|
| S.No. | auto |
| Service recipient Name & Address | Client |
| Country | Client country |
| Invoice No., Date, Currency, Amount | Invoice |
| Net Realisable value | Expected amount after known deductions (e.g. platform fee withheld by the payer). By default this equals the invoice amount. |
| Contract No. (if any) and Date | Contract, SOW or PO |
| Description of services | Invoice line summary |
| SAC Code | Invoice SAC (6-digit) |
| Remarks | e.g. “Paid via Deel (third party)”, “Advance received on dd-mm-yyyy”, “Pre-1 Oct invoice: excluded” |
Part 4 — Exporter’s declaration
The exporter declares that the particulars are true, and undertakes to realise the full value “on or before ……” through the named AD within the RBI period. The form is signed and dated by the exporter. easylancing pre-fills the realisation date as invoice date + 9 months (12 months if INR) and leaves the signature to the user.
Part 5 — Certification by the specified authority
Completed by the bank. The product leaves it blank.
Supporting documents
The regulations list none. Each AD’s policy decides (Reg. 19(1)(a)). The form’s wording (“corresponding invoice/gist of invoices”) suggests the bank expects: copies of the invoices, the contract/SOW where one exists, FIRA/e-FIRC for amounts already received, and possibly a covering letter (REPORTED/inference). The product generates: the EDF PDF in Annex format, a Part 2B schedule (CSV/XLSX), a covering letter, an invoice ↔ receipt mapping sheet, and a zip of the invoices.
4. Deadlines and computations
| Clock | Rule | Formula in product |
|---|---|---|
| EDF due | 30 days from the end of the invoice month |
end_of_month(invoice_date) + 30 days. Oct 2026 invoices → 30 Nov 2026; Nov invoices → 30 Dec; Dec invoices → 30 Jan; Jan invoices → 2 Mar (non-leap year). |
| EDF early-file window (non-software only) | on or before the payment date | informational only. Default to the 30-day rule for everyone (the software/non-software line is fuzzy) |
| Realisation & repatriation | 9 months from invoice date (12 months if invoiced or settled in INR) |
Date.shift(invoice_date, month: 9). Alert at T-60, T-30 and T-7 days, and on breach |
| AD extension | at the AD’s discretion, no cap | record the extension letter and new date |
| Reg. 13 restriction | unrealised more than 1 year after the due (or extended) date → future exports only against full advance or LC |
realisation_due + 1 year, red alert |
| GST Rule 96A (if exported under LUT) | pay IGST + 18% interest within 15 days after the later of 1 year or the FEMA period (including any extension), counted from the invoice date |
max(invoice_date + 1y, fema_due) + 15 days (see 20-gst…) |
5. Currency and INR value on the EDF
- The EDF records invoice currency and amount per row. Part 1 asks for the total in INR, in words.
- The regulations prescribe no conversion rate for this field (UNCERTAIN). Default: convert each invoice at the rate used on the invoice (GST Rule 34(2): GAAP rate on the date of supply, which is the RBI/FBIL reference rate or the bank TT rate on the invoice date, applied consistently). Show the rate and its source on the schedule.
6. Form number, submission and acknowledgement
- Form No.: the old regime generated SOFTEX/EDF numbers online. Under the new regime, banks issue or record their own reference (Razorpay calls it an “EDF number” for ICICI settlement). Never fabricate. Leave it blank. After submission, the user records the bank’s reference.
- Channel: bank-specific: portal (HDFC Trade-E-Bank REPORTED; ICICI Trade Online), email, or branch. The product keeps a bank directory of known channels, each entry with its source and “last confirmed” date, crowd-reported and moderated.
-
Status lifecycle in product:
draft → ready (user reviewed) → submitted (user marks, with date and channel) → acknowledged (bank ref recorded) → closed (all invoices realised or closed by declaration).
7. Edge cases and default treatment
| Case | Rule / evidence | easylancing default |
|---|---|---|
| Invoice dated before 1 Oct 2026, paid after | Savings clause; Reg. 20. Xflow and Gadhia say no EDF (REPORTED) | Exclude from the EDF. Flag “pre-regime invoice: old rules apply; confirm with your bank if asked”. Realisation clock: 9 months from export (old regs) |
| Invoices dated 14 Nov 2025 – 4 Jun 2026 | Old regs allowed 15 months during that window. The effect of the reversion is unclear (UNCERTAIN) | Alert at 9 months; show 15 months as the possible outer limit; recommend asking the bank |
| Advance received before the invoice | Reg. 10: advance and realisation through the same AD; tell both ADs if switching | Record it as an advance receipt. When the invoice is raised, add it to that month’s EDF with the remark “advance received” |
| Third-party payer (Deel, Upwork, Remote, client’s parent company) | Reg. 8: AD may permit if satisfied of bona fides. The EDF has third-party fields | Fill in the third-party fields; attach the platform contract/ToS excerpt. Warn: “your bank decides” |
| Money via PA-CB (Wise Business India, Skydo, Razorpay, Xflow, BriskPe…) | PA MD 11(h): the PA gives closure documents to “the AD bank of the exporter”. Which AD is meant is UNCERTAIN | File with the user’s own AD bank (where the INR lands) unless the provider or bank says otherwise. Attach the PA’s FIRA. Razorpay + ICICI: the EDF number may be needed before capture |
| Platform INR payout (Deel local transfer, Upwork Direct-to-Local-Bank, Payoneer, PayPal) | The bank sees a domestic INR credit; there may be no IRM to match | Still file the EDF. Close invoices ≤ ₹10 lakh by declaration; keep the platform FIRA/NOC. Escalate above ₹10 lakh |
| Invoice > ₹10 lakh | Closure needs actual realisation evidence | Require a FIRA/IRM before marking it realised |
| Short receipt (bank charges, FX, platform fee) | Reg. 6: reduction allowed by the AD, on declaration if ≤ ₹10 lakh | Record the shortfall reason; generate a reduction declaration |
| Write-off / client never pays | Reg. 6; Reg. 13 consequence after due + 1 year | Generate a write-off request letter; alert on the Reg. 13 date |
| INR invoice to a foreign client | 12-month realisation; GST condition (iv) needs RBI-permitted INR (e.g. SRVA) | Allow, but warn strongly; foreign-currency invoices are the default |
| Platform or marketplace income (Upwork, Fiverr, AdSense, app stores) | Whether it is “export of services” is UNCERTAIN | Treat as export: include in the EDF with platform name and country; flag for CA review |
| Software vs non-software | Determines whether the early-filing option exists | Ask the user; default to “software” for dev, design and digital content (broad definition) |
| No IEC | Not legally required for services; the form has an IEC field | Leave it blank or enter PAN per the bank’s instruction; suggest getting a free IEC if the bank insists |
| SEZ unit | Specified authority is the DC, SEZ | Out of scope for v1 (block, with a message) |
8. Penalties
- FEMA s.13 (REPORTED; India Code text not retrieved): up to 3× the sum involved, or up to ₹2 lakh where not quantifiable, plus up to ₹5,000 per day for continuing contraventions. Imposed by adjudication.
- Compounding under the Foreign Exchange (Compounding Proceedings) Rules, 2024 (VERIFIED, RBI FAQ).
- Reg. 13: automatic advance/LC-only restriction (VERIFIED).
- Banks may not penalise customers for regulatory delay (Reg. 19(3), VERIFIED).
- Practical effect: an open EDPMS entry can block e-BRC generation and weaken GST refund or zero-rating evidence (REPORTED).
9. Product rules derived from this document
| ID | Rule | Severity | Basis |
|---|---|---|---|
| EDF-001 | Every export invoice dated ≥ 2026-10-01 must belong to exactly one EDF (period = invoice month, bank = selected AD) | blocking for the “EDF complete” status | Reg. 3(2) VERIFIED |
| EDF-002 | EDF due date = end of month + 30 days; reminders at T-14, T-7, T-2 and due date | info | Reg. 3(2) VERIFIED |
| EDF-003 | Invoices before 2026-10-01 are excluded by default, with a flag | warning | REPORTED |
| EDF-004 | Mandatory before “ready”: PAN, exporter name and address, AD name and code, at least one Part 2B row, every row with client name, address, country, invoice no., date, currency, amount, description, SAC | blocking | Annex VERIFIED |
| EDF-005 | Third-party fields required when receipt payer ≠ invoice client | blocking (if a receipt exists) / warning (expected payer set) | Reg. 8 + Annex VERIFIED |
| EDF-006 | Realisation due = invoice date + 9 months (12 months if invoice currency is INR) | info → escalating alerts | Reg. 5 VERIFIED |
| EDF-007 | Invoice > ₹10 lakh cannot be marked “closed by declaration” | blocking | Reg. 4(2) proviso VERIFIED |
| EDF-008 | Never generate a Form No.; it is user-entered from the bank | blocking | design rule |
| EDF-009 | PA-CB receipts > ₹25 lakh in a single transaction are impossible; flag a data error | warning | PA MD 11(d) VERIFIED |
| EDF-010 | The submission step requires an explicit user attestation checkbox and is recorded in the audit log | blocking | legal design |
Change log
- 2026-10-03: first canonical version (research snapshot after 22 Sept amendment).