If you publish apps as an individual and receive store payouts into your personal account, RBI's 7 October 2026 statement that individuals providing services abroad are not required to report suggests you likely won't need to file an EDF — but the Regulations haven't been amended yet and RBI's FAQs are pending, so confirm with your bank. If your apps are published by a proprietorship, LLP or company, assume the EDF applies. App-store income also raises a question most freelancers never face: there's no client invoice per sale, so you have to work out with your bank and CA what the EDF row should be based on.
Key takeaways
- Individual developers are likely outside EDF reporting after 7 October 2026, but check with your bank until the FAQs arrive.
- App studios run as businesses should treat store payouts as software exports and file monthly.
- Store payouts come with statements, not client invoices — many developers raise one monthly invoice to the paying store entity; agree the approach with your CA and bank.
- Check where the payout actually comes from. A foreign remittance and a rupee credit from an Indian entity are treated very differently.
- Ad-network revenue and in-app purchase revenue may need separate treatment.
The individual question first
On 7 October 2026, RBI's Governor said individuals providing services abroad — including small software work — are not required to report, and the Deputy Governor said personal-contract transactions fall outside the reporting requirement. RBI promised FAQs.
For a solo developer, that's encouraging. But app-store income is unusual. You aren't providing a service to a specific foreign client under a personal contract; you're distributing software to the public through a store under the store's developer terms. Whether that fits the "individual" carve-out RBI described is exactly the kind of detail the FAQs may need to address.
So, if you're an individual:
- Ask your bank in writing whether it expects an EDF for your store payouts.
- Keep every monthly payout statement and the matching bank credit.
- Don't panic-file, and don't ignore the bank if it asks.
Our explainer on the 7 October RBI statement has the full context.
Where does your payout actually come from?
This matters more than anything else. App stores have different payout arrangements in different countries, and those arrangements change. Before assuming anything, look at your bank credit and the store's payout documentation.
| What you see | What it suggests | What to check |
|---|---|---|
| A foreign-currency inward remittance from an entity abroad | A cross-border payment for software — looks like an export | Purpose code on the FIRA; the paying entity's name and country |
| A rupee credit from an Indian entity, via domestic transfer | May not be an export remittance at all | Ask your CA how GST and FEMA view it |
| Payout via a third-party payment platform | The platform is a conduit | Keep the platform statement linking payout to store |
Check the store's current India help or payments pages for your account, rather than relying on forum posts — store arrangements are their own and we won't guess at them. If the money comes from an Indian entity in rupees, the FEMA export framework may not be the right lens at all; get advice.
For app studios: making the EDF work with payout statements
Say you're a business and your payouts are foreign remittances. The EDF wants one Part 2B row per invoice, with recipient, country, invoice number and date. Stores don't ask you to invoice them per sale, so you need a consistent document to declare.
A common practical approach is:
- Raise one invoice per store per month, addressed to the store entity named on the payout statement, for the payout amount (or the gross amount less the store's commission — agree which with your CA).
- Date it consistently, for example on the last day of the sales month or the payout statement date.
- List that invoice on the EDF for the month of the invoice date.
That's not a rule from the Regulations; it's a sensible way to create the paper trail the EDF assumes. Confirm the approach with your bank before your first filing.
A worked example: Pebblestack Games LLP
Pebblestack Games LLP, a fictional Pune studio, earns from two app stores and one ad network. Its October 2026 payouts, all received as foreign remittances in USD:
| Invoice | Date | Paying entity | Country | Amount | Source |
|---|---|---|---|---|---|
| PG/26-27/010 | 31-Oct-2026 | Store A (entity on statement) | Per statement | USD 8,420 | September sales, net of commission |
| PG/26-27/011 | 31-Oct-2026 | Store B (entity on statement) | Per statement | USD 5,190 | September sales, net of commission |
| PG/26-27/012 | 31-Oct-2026 | Ad network (entity on statement) | Per statement | USD 2,365 | September ad revenue |
Total USD 15,975. At ₹84 per USD, field 1.22 shows ₹13,41,900. The EDF is due 30 November 2026, with type of export "Software" and mode of delivery "Internet". As a software exporter, Pebblestack can file with its AD bank or with STPI.
Each invoice is under ₹10 lakh, so once realised, the bank may close them through Pebblestack's periodic ₹10 lakh declaration.
Ad revenue is worth a separate look. It's payment for ad inventory in your app, not for software sold — the SAC and purpose code may differ. Ask your CA and bank.
Codes and GST for studios
| Item | Starting point | Confirm with |
|---|---|---|
| SAC | 998314 (IT design and development) or other IT codes, depending on the revenue type | CA |
| Purpose code | P0807 (off-site software exports) is often relevant for software distributed abroad | Bank |
| GST | Export of services if Section 2(6) conditions are met; LUT avoids IGST | CA |
Digital app sales raise their own GST and income-tax questions, especially where the store acts as a marketplace. These sit outside the EDF and need a CA who understands app businesses. The EDF doesn't change your GST or income tax either way.
This is general information, not legal or tax advice.
Records every developer should keep
Business or individual, keep:
- monthly payout statements from each store and ad network
- the bank credit or FIRA for each payout, with purpose code
- your developer agreement acceptance and tax forms submitted to stores
- any invoices you raise to store entities
Our guide on how to read a FIRA shows what to check on each credit.
Frequently asked questions
Do individual app developers need to file the EDF?
RBI said on 7 October 2026 that individuals providing services abroad are not required to report. App-store income is a slightly unusual case, and the Regulations haven't been amended yet, so ask your bank and keep payout statements until RBI's FAQs clarify.
How can I file an EDF when I don't invoice the app store?
Many studios raise one monthly invoice to the store entity named on the payout statement and declare that invoice on the EDF. This isn't prescribed in the Regulations, so agree the approach with your CA and bank first.
What if my payouts come from an Indian entity in rupees?
Then the payment may not be a foreign remittance at all, and the EDF framework may not apply in the usual way. Ask your CA how GST and FEMA treat your specific payout arrangement.
Is app-store income "Software" on the EDF?
Revenue from selling or licensing apps generally fits "Software" in field 1.1. Ad revenue from in-app advertising may be different, so check with your bank and CA how to classify it.
Can my studio file the EDF with STPI instead of the bank?
Yes, for software exports you may file with your AD bank or STPI. STPI certification is no longer mandatory, and AD banks are specified authorities on par with STPI.
Bottom line
Solo developers should check with their bank and keep every payout statement; studios should create a monthly invoice trail and file on time. Build that invoice with our export invoice generator and declare it in the free EDF form generator.
This guide is general information for Indian businesses, not legal or tax advice. Rules and bank processes change — confirm specifics with your AD bank or chartered accountant.