Snapshot: 2026-10-03. Detail and citations are in 10–60 and in research/.
The headline (VERIFIED)
- New law. The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification FEMA 23(R)/2026-RB, dated 13 Jan 2026, Gazette CG-MH-E-15012026-269352) came into force on 1 October 2026. They replace the 2015 export regulations. A.P. (DIR Series) Circular No. 20 (16 Jan 2026) withdrew the Master Directions on Export and Import, along with every SOFTEX circular, from the same date.
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Every exporter of services must now file an Export Declaration Form (EDF). Under the old rules, services other than software needed no declaration. Now:
- The EDF goes to the “specified authority”, which for nearly all freelancers is the AD bank (STPI is also allowed for software).
- It is due within 30 days from the end of the month in which the invoice was raised (Reg. 3(2)).
- One EDF can cover all invoices of a month.
- There is no minimum amount and no exemption for individuals.
- Exporters of services other than software may instead file on or before the date payment is received.
- “Software” is defined broadly. It covers “any computer programme, database, drawing, design, audio/video signals, any information … in or on any medium other than … physical medium”. Developers are clearly software exporters. Designers and video and content creators very likely are too.
- SOFTEX is gone. It was folded into the EDF.
- Realisation deadline. The full export value must be realised and repatriated within 9 months from the invoice date, or 12 months if the invoice is in INR or settled in INR. The 22 Sept 2026 amendment (FEMA 23(R)/(1)/2026-RB) cut these from the 15/18 months in the original text. Many blogs still quote 15 months; they are out of date.
- ₹10 lakh per-invoice relief. For invoices up to ₹10 lakh, the bank may close the export record (EDPMS entry), and approve any reduction or write-off, on the exporter’s own declaration. This can be done quarterly in bulk. This does not exempt anyone from filing the EDF.
- Bank discretion. Banks set the channel, documents and format through their own policy and SOP (Reg. 19) and must publish them. As of 3 Oct 2026, RBI has issued no FAQ and no prescribed electronic channel, and banks are still settling their procedures. Axis Bank has published the form (“Annexure 6”, 24 Sept 2026).
- No bank penalties. Reg. 19(3): a bank may not levy a penalty on its customer for that customer’s regulatory delay. FEMA s.13 penalties (up to 3× the sum involved, REPORTED) are imposed by adjudication. If an export stays unrealised for more than one year after the due date, all further exports must be against full advance payment or an LC (Reg. 13).
The first deadline that matters
Invoices dated October 2026 → EDF due by 30 November 2026. Ship the minimum viable EDF generator before mid-November.
What this means for a typical freelancer
| Obligation | Who | Frequency | Where |
|---|---|---|---|
| Export invoice (GST-compliant if registered) | everyone | per engagement or month | own records, sent to the client |
| EDF for all export invoices of the month | every service exporter | monthly, within 30 days after month-end | AD bank (portal, email or branch, depending on the bank) |
| Proof of receipt (FIRA / e-FIRC / bank advice) mapped to invoices | everyone | per receipt | from the bank or payment aggregator |
| EDPMS closure declaration for invoices ≤ ₹10 lakh | everyone (if the bank asks) | quarterly (optional bulk) | AD bank |
| Realise within 9 months of the invoice | everyone | continuous | — |
| LUT (RFD-11) | GST-registered | yearly, before the first export of the FY | GST portal |
| GSTR-1 (Table 6A) and GSTR-3B (Table 3.1(b)) | GST-registered | monthly or quarterly (QRMP) | GST portal |
| ITR (presumptive tax under s.44ADA, now s.58 Sl. 3 of the Income-tax Act 2025) | everyone | yearly | income-tax portal |
| Advance tax (presumptive: 100% by 15 March) | if tax ≥ ₹10,000 | yearly | e-Pay Tax |
Important correction to a common belief: a GST-registered freelancer who issued any export invoice in a period cannot file a NIL return for that period (VERIFIED, GSTN NIL-return conditions exclude “zero rated supplies”). The product must calculate and report the exports. NIL filing applies only to months with no invoices, no advances, no RCM and no ITC.
The three facts the product depends on that are still UNCERTAIN
- Which bank receives the EDF when the money arrives through a payment aggregator (Wise Business, Skydo, Razorpay, Xflow…) or a platform payout (Deel or Upwork local INR transfer, Payoneer, PayPal). The options are the user’s own bank, where the INR lands, or the aggregator’s collection bank. Providers disagree. Razorpay says ICICI-settled merchants need the EDF number before capture. Default: the user’s own AD bank. The product tells the user to confirm with the bank.
- Bank-by-bank format and channel. Unknown for most banks. We will collect this from users and keep a “bank directory” up to date.
- Transition for invoices dated before 1 Oct 2026 that are paid after it. The consensus (REPORTED) is that no EDF is needed and the old rules apply. Default: flag these invoices and suggest asking the bank.
Strategic implication
Payment rails (Skydo, Razorpay, Xflow, Infinity) only cover money that flows through their own rails, and none has a live self-serve EDF generator (Skydo’s tool is “being built”). Variabl is the closest direct competitor (CA-led, ₹0–14,999 a year). easylancing’s opening: one bank-agnostic and rail-agnostic ledger that covers invoices, receipts, the EDF, realisation tracking and GST data. It is self-serve, user-reviewed and cites its sources.