A doctor in India who consults with patients or clinics abroad by video, and is paid in foreign currency, is exporting a service. Whether that means filing the EDF depends on how you practise. On 7 October 2026, RBI said individuals providing services abroad are not required to report, and that FAQs would follow, so a doctor consulting in their personal capacity is likely outside the requirement. A clinic, hospital, partnership or company that bills foreign patients or platforms should assume the EDF applies.
Key takeaways
- RBI's Governor said on 7 October 2026 that individuals providing services abroad need not report; the Deputy Governor said personal-contract transactions are outside the requirement.
- The Regulations have not been amended yet, so individual doctors should check with their bank until RBI's FAQs are out.
- Clinics, hospitals, firms, LLPs and companies billing foreign clients should file one EDF a month.
- Keep invoices, platform statements and FIRAs, and keep patient details out of all of them.
- The EDF does not change income tax or GST. Medical services have their own GST treatment, which your CA should confirm.
Three ways doctors earn from abroad
Teleconsultation income reaches Indian doctors through quite different routes, and the route matters more than the medicine.
| How you work | Who pays you | Likely EDF position | Practical step |
|---|---|---|---|
| Personal second opinions for overseas patients | Patient, directly | Individual: covered by RBI's 7 October statement | Ask your bank; keep receipts |
| Doctor on a foreign telehealth platform | The platform | Individual if contracted personally; check with bank | Keep platform statements and FIRAs |
| Clinic or hospital billing foreign patients or insurers | Patient, insurer or partner hospital | Business: assume covered | File monthly EDF |
| Radiology or pathology reporting company | Foreign hospitals or groups | Business: covered | File monthly EDF |
| Professional LLP of specialists | Platforms or hospitals abroad | Business: covered | File monthly EDF |
If you practise as an individual but have set up a proprietorship with a trade name and current account for your foreign work, the safer assumption is that you should file. Our explainer on who must file the EDF goes through each structure.
What RBI said, and what has not changed
The new export regulations took effect on 1 October 2026. They require service exporters to file an EDF for each month's invoices within 30 days from the end of that month. On 7 October 2026, the Governor said individuals providing services abroad, giving tutoring and small software work as examples, are not required to report. The Deputy Governor said personal-contract transactions are outside the requirement. RBI said FAQs would follow.
Medicine was not named, but the principle, individuals and personal contracts, would seem to apply to a doctor consulting in their own name. Until the FAQs arrive, banks may still query incoming payments. A short conversation with your bank now is better than a held remittance later. This is general information, not legal or tax advice.
Two doctors, two answers
Dr Kavya Nair, a Kochi dermatologist, gives about ten video second opinions a month to patients in the Gulf and the UK. Patients pay her directly, roughly ₹4,000 to ₹6,000 per consultation, into her personal account. She works as an individual, so she asked her bank whether it expected anything until RBI's FAQs; the bank said it would follow the FAQs and asked her to keep payment records.
Lakeview Teleradiology LLP, a Bengaluru partnership of five radiologists, reports scans overnight for two hospital groups in Australia and one in the US, invoicing monthly. In October 2026 it raised three invoices totalling about ₹38 lakh. As an LLP billing foreign hospitals, it filed one EDF with three rows in Part 2B, due 30 November 2026, with "Services" at field 1.1 and "Internet" at field 1.4.
Records every teleconsulting doctor should keep
Even if you never file an EDF, good records protect you for tax and banking.
- Invoices or receipts for each consultation or monthly bill: your name or practice, the payer, the country, date, currency and amount. Our free payment receipt maker works well for individual consultations.
- Platform statements if a telehealth platform pays you, linking each payout to the period it covers.
- FIRAs from your bank for each inward remittance, with the purpose code. Check the code fits health services; ask the bank which code it uses.
- A simple register of amounts received and dates.
Keep patient data out
Never put patient names, conditions or identifiers on invoices sent to banks, in EDF descriptions or in letters about remittances. "Teleconsultation services, October 2026" is enough. Patient confidentiality obligations apply regardless of FEMA.
GST and income tax
The EDF is a FEMA declaration. It does not change your tax position.
- Income tax: foreign consultation fees are part of your professional income if you are a resident. Many doctors use presumptive taxation; confirm with your CA under the current Income-tax Act.
- GST: many healthcare services provided by clinical establishments and medical practitioners are treated specially under GST, but the rules are specific and online consultations for foreign patients raise export questions. Your CA should advise on registration and treatment.
- Foreign tax: if a foreign platform withholds tax, you may be able to claim credit in India.
Professional registration and telemedicine rules in the patient's country are a separate matter again, and nothing to do with FEMA.
Frequently asked questions
Does a doctor giving online consultations to foreign patients need to file the EDF?
If you consult as an individual, RBI said on 7 October 2026 that individuals providing services abroad are not required to report. The Regulations have not changed yet, so check with your bank until RBI's FAQs are published.
Does a hospital or clinic billing foreign patients need to file?
A clinic, hospital, partnership, LLP or company that invoices foreign patients, insurers or hospitals for services should assume the EDF applies. It files one EDF per month for months with export invoices.
What if a telehealth platform pays me rather than the patient?
The platform changes who pays, not your status. If you contract personally with the platform, you are likely an individual; if you contract through a practice entity, assume the EDF applies. Keep platform statements and FIRAs either way.
Can I mention patient details in the EDF or invoice?
No. Describe the service generally, such as "teleconsultation services", and keep identifiable patient information off all banking and FEMA documents.
Bottom line
Doctors consulting abroad in their own name are likely outside EDF reporting, pending RBI's FAQs; practices and companies should file monthly. Either way, keep tidy receipts and FIRAs, without patient details. If your practice needs to file, use our 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.