A private limited company exporting services must file the EDF every month for its export invoices, and unlike individuals, there is no doubt about coverage. The practical questions for a company are governance ones: who is authorised to sign Part 4, how the board records that authority, and what internal checks stop a wrong or late form going to the bank. Get those right once and the monthly filing becomes a routine task any trained finance executive can run.
Key takeaways
- Companies are clearly covered by the 2026 Regulations. File one EDF per month, within 30 days from the end of the invoice month.
- Part 4 should be signed by a person authorised by the company and recorded with the AD bank, usually a director or an officer authorised by board resolution.
- Use a maker-checker process: one person prepares, another reviews against the invoice register before signing.
- Keep an EDF register and a monthly folder; auditors and banks will ask for the trail.
- Plan for absences: have at least two authorised signatories on record with the bank.
Who signs the EDF for a company
Part 4 is the exporter's declaration. For a company, a natural person signs on its behalf, and the bank will expect that person's authority and signature to be on its records.
| Signatory option | When it works | What to have in place |
|---|---|---|
| Managing director or director | Small companies, founders handle compliance | Director already a signatory on the account |
| CFO or finance head | Mid-sized companies | Board resolution authorising signing of export documents; bank has specimen signature |
| Company secretary or other officer | Where internal policy assigns it | Same as above |
| Any two jointly | Companies with joint signing mandates | Ensure the mandate covers export declarations, not just payments |
If the person who should sign is not on the bank's records, fix that first. A board resolution authorising named officers to sign export declarations and related bank correspondence, followed by an update to the bank, is the usual route. Our board resolution for bank account and signatory change letter formats help.
Sample board resolution wording
Companies often pass a short resolution like this (adapt with your company secretary or CA):
"RESOLVED THAT Mr/Ms [name], Director, and Mr/Ms [name], Chief Financial Officer, be and are hereby severally authorised to sign, execute and submit Export Declaration Forms, declarations of realisation and related correspondence with the company's Authorised Dealer bank(s) under the Foreign Exchange Management Act, 1999 and regulations made thereunder, on behalf of the company."
"Severally" means either can sign alone. If you want both to sign together, say "jointly". Give the bank a certified copy.
Internal controls that actually help
A company's EDF process should survive an audit and a staff change. A simple control set:
- Invoice register as the source. The EDF is prepared from the month's export invoices in the accounting system, filtered by invoice date, not from memory or email.
- Maker-checker. A finance executive prepares the EDF; a second person checks every row against the register: invoice number, date, currency, amount, recipient, SAC.
- Total reconciliation. The rupee total in field 1.22 reconciles to the export revenue in the books for the month, using the company's chosen exchange rate policy.
- Signatory review. The signatory sees the checked EDF and the register summary before signing.
- Submission log. Date submitted, channel used, acknowledgement reference.
- Realisation tracking. A monthly report of open invoices and their 9-month deadlines goes to the finance head.
- Exception handling. Any credit note, cancellation or short payment after filing is reported to the bank in writing, and logged.
Our article on keeping an EDF register has a template structure.
Worked example: Northstar Health Tech Pvt Ltd
Northstar Health Tech Pvt Ltd, Bengaluru, builds healthcare software for clients in the US and UK. It has 60 staff and a three-person finance team.
Its planned process for October 2026 invoices:
- 2 November: the accounts executive exports October export invoices: nine invoices, USD 74,300 and GBP 12,600.
- 3 November: the finance manager checks each row against the register, confirms any credit notes are reflected, and reconciles the rupee total of ₹76,27,200 to the books. That figure is USD 74,300 at ₹84 (₹62,41,200) plus GBP 12,600 at ₹110 (₹13,86,000).
- 4 November: the CFO, authorised by board resolution and on the bank's records, signs Part 4.
- 4 November: the executive submits via the bank's published channel and logs the acknowledgement.
- Ongoing: the monthly realisation report flags invoices approaching 6 months unpaid.
The due date is 30 November 2026, so the company keeps 26 days in hand.
When the CFO is on leave, the managing director signs instead; both are authorised severally and both are on the bank's records.
What auditors and banks will look for
Statutory auditors and internal auditors increasingly ask about FEMA compliance for exporters. Be ready to show:
- EDFs for each month with export invoices, with acknowledgements.
- A reconciliation of export revenue in the books to EDF totals.
- Realisation status of each invoice, with FIRAs.
- Extension approvals from the bank for any invoice past 9 months.
- Board resolution authorising signatories.
Missing EDFs or long-open EDPMS entries can lead to blocked eBRCs, GST refund problems and potential FEMA consequences, so auditors take them seriously.
Special situations for companies
- Multiple GSTINs or branches: the EDF can still be filed by the company, but make sure invoices from each registration are included and GSTIN in field 1.8 reflects the invoicing registration. Ask your bank how it prefers multi-GSTIN exporters to file.
- Change of directors: update bank signatories immediately; an EDF signed by a director who has resigned is a problem.
- Merger or change of name: inform the bank and update the EDF exporter details from the effective date.
- Group companies: if you bill a foreign parent or affiliate, see our article on intra-group billing.
The EDF does not change your GST or income-tax obligations. This is general information, not legal or tax advice.
Frequently asked questions
Who should sign the EDF for a private limited company?
A person authorised by the company, usually a director or an officer such as the CFO authorised by board resolution, whose signature is on the AD bank's records. Keep at least two authorised signatories to cover absences.
Does a company need a board resolution to file the EDF?
There is no special EDF resolution prescribed, but a resolution authorising named officers to sign export declarations and bank correspondence is good governance and helps the bank accept the signatory. Directors already on the bank mandate may suffice; ask your bank.
Can a finance executive sign the EDF?
Only if the company has authorised them and the bank has their specimen signature. Otherwise they can prepare and submit the form, while an authorised signatory signs Part 4.
What records should a company keep for EDFs?
Monthly EDFs with acknowledgements, the export invoice register, reconciliations to the books, FIRAs, realisation status and any extension approvals, plus the board resolution on signatories.
Is a private limited company with one foreign client required to file?
Yes. There is no minimum number of clients or value threshold for filing. One EDF per month covers all that month's export invoices, even if it is a single row.
Bottom line
For companies, the EDF is a governance task: authorised signatories, a maker-checker review and a clear trail. Prepare each month's form on the free EDF form generator and keep signatory records current with the bank.
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.