If your business operates from a unit inside a Special Economic Zone, your EDF does not go to your bank. Under the 2026 Regulations, units in an SEZ submit the EDF to the SEZ Development Commissioner, the specified authority for the zone, while the same company's non-SEZ offices file with their AD bank. Everything else about the form, from Part 2B rows to the Part 4 declaration, stays the same.
Key takeaways
- SEZ unit: EDF to the Development Commissioner. Non-SEZ office of the same company: EDF to the AD bank (or STPI for software).
- Field 1.5 (category of exporter) should read SEZ for exports made by the SEZ unit.
- The filing deadline is the same: within 30 days from the end of the month in which the invoice is raised.
- Realisation rules are the same: 9 months from the invoice date for services, 12 months for rupee invoices.
- Your AD bank still receives the money and is still part of the realisation and EDPMS trail. Keep both offices informed.
Why the SEZ route is different
An SEZ unit already reports to the Development Commissioner's office for a range of approvals and returns. The 2026 Regulations make that office the specified authority for EDFs from units in the zone too, so export declarations sit alongside the unit's other SEZ records.
Services outside an SEZ go to the AD bank, and software outside an SEZ can go to the AD bank or STPI. Inside the zone, the route is the Development Commissioner, regardless of whether the service is software or not.
| Where the exporting unit sits | What it exports | Specified authority for the EDF |
|---|---|---|
| Inside an SEZ | Software or other services | SEZ Development Commissioner |
| Outside an SEZ (DTA) | Services other than software | AD bank |
| Outside an SEZ (DTA) | Software | AD bank or STPI |
| 100% EOU | Services | Confirm with your AD bank |
The glossary entry for Development Commissioner explains the role in more detail.
What changes on the form itself
Very little. The Annex is the same EDF for every exporter. A few fields need attention:
- 1.1 Type of export: Services or Software, as for anyone else.
- 1.5 Category of exporter: select SEZ. This is the field that tells the reader the unit's status.
- 1.6 AD code and 1.10 AD bank: still your bank, because the money lands there.
- 1.11 Exporter name and address: the SEZ unit's address as registered, not the corporate head office if that sits elsewhere.
- Part 2B: one row per invoice raised by the SEZ unit, with the SAC code and contract details, exactly as for non-SEZ exporters.
- Part 5: completed by the specified authority, here the Development Commissioner's office.
How the Development Commissioner's office wants the EDF submitted, whether through an online system, physical copies or both, is a practical question for that office. Ask your SEZ compliance contact or the zone's office directly rather than assuming the bank's process applies.
A company with one foot in each world
Many technology companies have an SEZ unit and a regular office. Take Tidewater Systems Pvt Ltd: an SEZ unit in Chennai handling product engineering, and a DTA office in Bengaluru that sells consulting to the same overseas clients.
In January 2027, Tidewater raises:
| Raised by | Invoice | Client | Amount | Service |
|---|---|---|---|---|
| SEZ unit, Chennai | TWS-SEZ/0141 | Arbor Mobility Inc, USA | USD 48,000 | Software development |
| SEZ unit, Chennai | TWS-SEZ/0142 | Lindqvist AB, Sweden | EUR 19,500 | Software development |
| DTA office, Bengaluru | TWS-BLR/0377 | Arbor Mobility Inc, USA | USD 9,000 | IT consulting |
Tidewater files two separate EDFs:
- EDF 1 (SEZ unit): invoices 0141 and 0142, category SEZ, submitted to the Development Commissioner.
- EDF 2 (DTA office): invoice 0377, category "Others" (or as your bank advises), submitted to the AD bank.
Both are due by 2 March 2027, because January invoices fall due then (February 2027 has 28 days). Mixing SEZ and DTA invoices on one form would muddle the specified authority and the category field, so keep them apart from the start. A separate invoice series for each unit, as Tidewater uses, makes this almost automatic.
Realisation and the bank's role
Filing with the Development Commissioner does not take the bank out of the picture. Foreign money still arrives through your AD bank, which issues the FIRA or bank advice, and export data still flows into EDPMS for monitoring. The full value must be realised within 9 months from the invoice date (12 months for rupee invoicing), and extensions are requested on reasoned grounds.
In practice, SEZ finance teams often keep two trackers: one for what has been filed with the Development Commissioner, and one for what has been realised at the bank. Reconcile them monthly. If the bank cannot see an EDF it expects, or vice versa, it is far easier to sort out in month two than in month eight. Our year-end reconciliation guide shows a layout that works.
GST is a separate track
Supplies from an SEZ unit to overseas clients are exports of services when the conditions in Section 2(6) of the IGST Act are met, and exports are zero-rated. The EDF does not change your GST or income-tax position. SEZ units also have their own GST rules for supplies to and from the zone, which are beyond this article; check them with your CA. This is general information, not legal or tax advice.
Practical checklist for SEZ finance teams
- Confirm in writing how the Development Commissioner's office accepts EDFs and what it returns as acknowledgement.
- Use a distinct invoice series for the SEZ unit.
- Fill field 1.5 as SEZ on every SEZ EDF.
- Keep the AD bank informed so inward remittances can be matched without holds.
- Track the 9-month realisation date per invoice and request any extension before it lapses.
- Store the signed EDF, acknowledgement and FIRA together for each month.
Frequently asked questions
Where does an SEZ unit file its EDF for services?
With the SEZ Development Commissioner, who is the specified authority for units in the zone. This applies to software and other services alike. A non-SEZ office of the same company files with its AD bank instead.
What should an SEZ unit select as category of exporter on the EDF?
Select SEZ in field 1.5. The other options are Custom DTA units, 100% EOU, Warehouse export and Others. The category should match the unit that raised the invoices on that EDF.
Is the EDF deadline different for SEZ units?
No. The EDF is due within 30 days from the end of the month in which the invoice was raised. October 2026 invoices are due by 30 November 2026, and January 2027 invoices by 2 March 2027.
Can one EDF cover both SEZ and non-SEZ invoices of the same company?
It should not. The two units have different specified authorities and different categories in field 1.5. Prepare a separate EDF for each and submit them to the right office.
Does the SEZ unit still need to deal with its AD bank?
Yes. The money arrives at the AD bank, which issues the FIRA or advice and participates in realisation monitoring. Keep the bank informed about your EDFs so credits and EDPMS entries can be matched.
Bottom line
For SEZ units the form is familiar; only the destination and the category field change. Keep SEZ and DTA invoices on separate EDFs and confirm the Development Commissioner's submission process early. The free EDF form generator lets you set the category to SEZ and build your Part 2B rows, and the EDF due dates table keeps every month's deadline in view.
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.