The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 are RBI's new rulebook for declaring exports and bringing the money home. They took effect on 1 October 2026 and, for service exporters, boil down to three duties: declare your invoices on a monthly EDF, realise the full value within the allowed period, and let your bank close each entry once you are paid.
Key takeaways
- Issued by RBI as Notification No. FEMA 23(R)/2026-RB dated 13 January 2026; in force from 1 October 2026.
- They replace the earlier export regulations and abolish SOFTEX; software joins all other services on one EDF.
- File the EDF within 30 days from the end of the invoice month; one form can cover the whole month.
- Realise services exports within nine months of the invoice date, or twelve months for rupee invoicing.
- Invoices up to ₹10 lakh can be closed on a simple declaration of realisation.
Where the rules come from
FEMA, the Foreign Exchange Management Act, 1999, gives RBI power to frame regulations on foreign exchange transactions, including exports. Under that power, RBI notified the 2026 Regulations on 13 January 2026, giving exporters and banks nearly nine months to prepare.
Two documents work together:
| Document | Who it speaks to | What it does |
|---|---|---|
| FEMA (Export and Import of Goods and Services) Regulations, 2026 | Exporters and importers | Sets the legal duties: declare, realise, repatriate |
| RBI (Export and Import of Goods and Services) Directions, 2026 | AD banks | Tells banks how to receive, record and monitor declarations |
RBI amended some provisions on 22 September 2026, shortly before the start date. That is a good reason to read the current text on the >RBI notification page rather than rely on a copy saved in January. Our article on where to find the official EDF rules explains how the pieces fit.
What changed for service exporters
Before October 2026, the picture was uneven. Software exporters filed SOFTEX forms, often through STPI. Goods exporters used shipping bills. Most other service exporters had no specific export declaration at all.
The 2026 Regulations simplify that into a single form for everyone: the Export Declaration Form in the Annex. For goods at EDI ports, the shipping bill itself serves as the EDF, so that process stays largely the same. The big shift is on the services side:
- SOFTEX is gone. Software exports go on the EDF.
- AD banks became specified authorities for software, on par with STPI. STPI certification is no longer mandatory.
- Non-software services now have a clear monthly declaration, filed with the AD bank.
- SEZ units file with the SEZ Development Commissioner.
The duties, one by one
1. Declare
Regulation 3(2) requires the EDF within 30 days from the end of the month in which the invoice was raised. Invoices dated in October 2026 are due by 30 November 2026; January 2027 invoices are due by 2 March 2027 because February is short. For services other than software, you may instead submit on or before the date payment is received.
Regulation 3(2)(a) lets one EDF cover all of a month's service exports to one or more recipients. Every invoice is a row in Part 2B.
2. Realise
Regulation 5(1)(a) sets the realisation period: nine months from the invoice date for services, or twelve months where you invoice and settle in Indian rupees. The AD bank can extend that on a reasoned request.
3. Close the loop
Once you are paid, the bank closes the entry. Regulation 4(2) allows invoices up to ₹10 lakh (or the foreign-currency equivalent) to be closed on your declaration of realisation. That declaration is separate from the EDF and can be given periodically, for example every quarter. Above ₹10 lakh, the bank works from the invoice, payment evidence such as a FIRA, and your matching instructions.
What banks must do
The bank side matters because it explains what you will experience.
- EDPMS entry within five working days (Regulation 18). Your EDF becomes a set of open items in the Export Data Processing and Monitoring System.
- Published acceptance policies (Regulation 19). Each bank must say how it accepts EDFs, so the channel varies: branch, email or a net-banking trade portal.
- Discretion on delays. The bank may accept a delayed EDF for reasonable cause and may extend the realisation period.
Because channels vary, ask your branch or relationship manager how your bank wants to receive the form. Our guide on submitting the EDF to your bank lists the questions to ask.
Who is covered
Proprietorships, partnership firms, LLPs and companies that invoice foreign clients for services should assume they are covered. Individuals are less clear. On 7 October 2026, RBI's Governor said individuals providing services abroad are not required to report, and the Deputy Governor said personal-contract transactions are outside the reporting requirement. RBI said it would issue FAQs, but the Regulations themselves had not changed. Until those FAQs appear, individuals should check with their bank.
Invoices raised before 1 October 2026 are widely reported to fall outside the EDF requirement. Confirm that with your bank if you have large pre-October invoices still unpaid.
A month under the new rules
Here is what compliance looks like for Tarang Consulting Pvt Ltd, a Hyderabad firm with four foreign clients:
| Date | Action |
|---|---|
| Through November 2026 | Raise invoices as work is delivered; four invoices totalling ₹38,40,000 |
| By 30 December 2026 | Submit one EDF listing all four invoices |
| Within five working days of submission | Bank enters the EDF into EDPMS |
| As payments arrive | Bank matches each payment to its invoice row |
| End of each quarter | Give a declaration covering paid invoices up to ₹10 lakh each |
| Before nine months from each invoice date | Chase anything unpaid; seek an extension if needed |
None of this touches GST or income tax. The EDF is a FEMA declaration; zero-rating, LUT and tax filings carry on separately. This summary is general information, not legal or tax advice.
What happens if you ignore it
The consequences are practical before they are legal. Your bank may hold an incoming foreign credit until the EDF is filed. Unmatched entries stay open in EDPMS, which can block eBRCs and complicate GST refunds. FEMA penalties under Section 13 are possible for contraventions. A simple monthly routine prevents nearly all of it.
Frequently asked questions
When did the FEMA export regulations 2026 come into force?
They came into force on 1 October 2026. RBI notified them on 13 January 2026 as Notification No. FEMA 23(R)/2026-RB, and amended some provisions on 22 September 2026 before the start date.
Do the 2026 Regulations apply to service exporters?
Yes. Businesses exporting services, including software, must declare their invoices on the EDF. Individuals working in a personal capacity have been told by RBI they are not required to report, but should confirm with their bank until FAQs are issued.
What replaced SOFTEX?
The EDF. Software exports are now declared on the same single form as other services, filed with the AD bank or STPI. AD banks are specified authorities on par with STPI.
How long do I have to get paid?
Nine months from the invoice date for services, or twelve months where you invoice and settle in Indian rupees. Your AD bank can extend the period if you make a reasoned request.
Do the new rules change GST on exports?
No. The Regulations deal with foreign exchange declarations and realisation. GST treatment of export of services as a zero-rated supply, and your LUT, continue under GST law.
Bottom line
The 2026 Regulations ask service exporters for a monthly declaration, timely payment and a closed loop with their bank. Learn the two dates that matter (the EDF deadline and the realisation window) and the rest follows. Start with the free EDF form generator and keep the due date table handy.
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.