If your business invoices foreign clients for services and is set up as a company, LLP, partnership firm or sole proprietorship, assume you must file the EDF from 1 October 2026. The only group RBI has signalled may be outside the requirement is individuals working on personal contracts, and even that position is waiting on formal FAQs.
Key takeaways
- Companies, LLPs, partnership firms and proprietorships exporting services should treat the EDF as mandatory under the 2026 Export and Import Regulations.
- On 7 October 2026, RBI's Governor said individuals providing services abroad are not required to report; RBI said it will issue FAQs. The Regulations' text has not changed yet.
- A proprietorship is not the same as "an individual" for this purpose in practice — if you run a registered business, plan to file.
- Where you file depends on where you sit: AD bank for most, AD bank or STPI for software, the Development Commissioner for SEZ units.
The rule in one paragraph
The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, notified by RBI on 13 January 2026 and in force from 1 October 2026, require exporters to declare exports on the EDF, the form in the Annex to the Regulations. For services, you file within 30 days from the end of the month in which the invoice was raised. One EDF can cover all your service invoices for the month, to any number of foreign clients. You can read the notification on the >RBI website; RBI amended some provisions on 22 September 2026, so always check the current text.
The question most people actually have is not "what is the rule" but "does it apply to me". That depends on how you are organised.
Entity by entity
| Your set-up | Should you file the EDF? | Where it usually goes |
|---|---|---|
| Private or public limited company | Yes — assume covered | AD bank (or SEZ Development Commissioner if an SEZ unit) |
| LLP | Yes — assume covered | AD bank |
| Partnership firm | Yes — assume covered | AD bank |
| Sole proprietorship | Yes — assume covered | AD bank |
| Software exporter outside an SEZ | Yes | AD bank or STPI |
| Individual on personal contracts (tutor, small freelance gigs) | RBI says not required; FAQs awaited — check with your bank | — |
Companies
A company that bills a foreign client — whether it is a 200-person IT services firm or a two-founder SaaS startup — is squarely within the Regulations. Indian subsidiaries billing their foreign parent are exporters too, and their cross-charges are service exports. If you run a company, the only open questions are operational: which bank, which channel, which invoices go on which month's form.
LLPs and partnership firms
These are business entities with their own PAN and, usually, their own current account. When Meridian Advisory LLP invoices a client in Singapore, the LLP is the exporter. The EDF goes in the LLP's name, signed by a designated partner or an authorised signatory.
Sole proprietorships
This is where confusion lives. Legally, a proprietorship and its owner share one PAN, so some proprietors assume the individuals' clarification covers them. Be careful. If you trade under a business name, hold GST registration, issue tax invoices and receive money into a current account, you look like a business to your bank. The advice in RBI's 7 October remarks was framed around individuals providing services abroad and personal contracts. Until the FAQs say otherwise, proprietorships should plan to file.
Individuals
At RBI's policy press conference on 7 October 2026, the Governor said individuals providing services abroad, such as tutoring or small software work, are not required to report. The Deputy Governor said transactions under personal contracts are outside the reporting requirement. RBI said it would issue FAQs. Our explainer on what the 7 October statement means goes into more detail.
The practical advice for individuals is simple: ask your bank how it is treating your inward remittances until the FAQs are published.
Two examples that show the line
Ritika, a Delhi-based English tutor. She teaches four students in Dubai over video, invoicing in her own name, with money arriving in her savings account. She is not GST-registered and has no business name. Based on RBI's 7 October remarks, she appears to fall in the individuals category. She should still keep invoices and FIRAs and ask her bank whether it expects anything from her.
Ritika Learning Studio (proprietor: Ritika). Two years later, Ritika registers for GST, opens a current account in the studio's name and hires two tutors. She now invoices schools in the UAE for ₹3,60,000 a month. This looks like a business. She should file a monthly EDF covering every invoice, and our guide on EDF for sole proprietorships walks through the details.
The person is the same; the set-up is different. That difference is what your bank will look at.
Where each type of exporter files
Filing location follows the type of service and where your unit sits, not your entity type.
- Services other than software, outside an SEZ: file with your AD bank — normally the bank where the foreign money lands.
- Software, outside an SEZ: file with your AD bank or with STPI. AD banks are now specified authorities on par with STPI, and STPI certification is no longer mandatory.
- SEZ units: file with the SEZ Development Commissioner.
Each bank publishes its own policy on how it accepts EDFs, so whether you submit at the branch, by email or through a trade portal varies. Ask your branch or relationship manager.
What filing actually involves
For a covered business, the monthly routine is short once set up:
- List every service invoice raised to foreign clients during the month.
- Fill one EDF with each invoice as a row in Part 2B.
- Sign the Part 4 declaration and submit by the 30-days-after-month-end date (or, for services other than software, on or before the date you receive payment).
- Track realisation: services must be fully paid within 9 months from the invoice date, or 12 months where invoiced in rupees.
Our free EDF form generator lays out all the parts and fields so you can produce a clean form in a few minutes.
This is general information, not legal or tax advice. If your situation sits on the line between individual and business, take it to your CA and your bank.
Frequently asked questions
Does a one-person company need to file the EDF?
Yes. A one-person company is still a company, separate from its owner, so it should treat the EDF as mandatory for service exports. The individuals clarification from 7 October 2026 is about natural persons on personal contracts, not incorporated entities.
I am a freelancer with GST registration. Am I an individual or a business?
There is no official answer yet. RBI's remarks referred to individuals and personal contracts, and FAQs are awaited. If you hold GST registration, use a trade name and a current account, your bank may treat you as a business, so ask your bank how it will handle your remittances and keep EDF-ready records either way.
Do Indian subsidiaries of foreign companies file the EDF?
Yes. An Indian subsidiary billing its foreign parent or group companies is exporting services, and those invoices belong on the monthly EDF. Intra-group billing gets no exemption simply because the client is related.
Does the EDF apply to invoices raised before 1 October 2026?
It is widely reported that the EDF does not apply to invoices raised before 1 October 2026, when the 2026 Regulations came into force. Confirm with your bank, especially for older invoices paid after that date.
If I am not required to file, should I still keep records?
Yes. Invoices, contracts, FIRAs and bank advices support your income tax return and any GST position, and they will help if the FAQs end up covering your case. Good records cost little and save a lot of back-and-forth later.
Bottom line
If you invoice foreign clients through a company, LLP, firm or proprietorship, plan to file an EDF every month from October 2026 onwards. Individuals should wait for RBI's FAQs and check with their bank meanwhile. Covered businesses can start with the free EDF form generator and the complete EDF guide.
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.