Updated 11 November 2026. A plain-language summary for business owners and freelancers, not legal or tax advice. Confirm how your bank applies the rule before you change your process.
Short answer: RBI's FEMA (Export and Import of Goods and Services) (Second Amendment) Regulations, 2026 (notification FEMA 23(R)/(2)/2026-RB, dated 2 November 2026, effective from 1 October 2026) make the Export Declaration Form (EDF) for service exports "deemed submitted" in two cases. For resident individuals (freelancers, consultants, creators) there is no amount limit. For companies, LLPs and firms it applies only when the inward remittance for a service is not more than ₹10 lakh. In both cases you still have to give your bank the payment details it needs to credit your account. Above ₹10 lakh, businesses file the EDF as before.
What changed, in one table
| Who | Before | From 1 October 2026 |
|---|---|---|
| Resident individual exporting services | Declare the full export value in the EDF | EDF deemed submitted once you give the bank the payment-receipt information. No monetary cap. |
| Company / LLP / firm, remittance up to ₹10 lakh | Declare in the EDF | EDF deemed submitted, on the same condition |
| Company / LLP / firm, remittance above ₹10 lakh | Declare in the EDF | No change: file the EDF within the normal time limit |
| Import of services (not by resident individuals) | Bank reports in IDPMS | Bank must enter details in IDPMS within five working days only where the invoice or contract value is above ₹10 lakh |
The amendment is summarised by CorpLawUpdates and TaxGuru. The official text is on the RBI notifications page.
What is the EDF, and why does this matter?
The EDF is the declaration an exporter gives to its authorised dealer (AD) bank so that export value and the money received against it can be tracked under FEMA. Under the new export-import regulations notified in January 2026, a service exporter generally declares the full export value within 30 days from the end of the month in which the invoice is raised.
For a freelance developer billing a US client every month, or a small agency with many low-value overseas invoices, that meant paperwork for every receipt. The new provisos let the bank treat the declaration as done when the money comes in and you give the details needed to credit it.
Who is a "resident individual"?
The amendment adds a definition: a person resident in India who is a natural person. That covers individual freelancers and consultants receiving money in their own name. It does not cover a proprietorship that operates through a company, an LLP or a partnership firm. Those are tested against the ₹10 lakh limit.
How the ₹10 lakh test works for businesses
- It is per inward remittance, per service. It is not an annual turnover limit. A firm with crores of export turnover can still use the deemed route for each receipt of ₹10 lakh or less.
- "Not more than" includes exactly ₹10 lakh (or its foreign-currency equivalent).
- Instalments are a grey area. TaxGuru points out that the rule does not clearly say what happens when one large invoice is paid in several receipts under ₹10 lakh. Do not split payments to fit under the limit. Ask your AD bank how it will treat such cases.
What does not change
- Realisation time limits. As amended in September 2026, service export proceeds generally have to be realised and repatriated within nine months from the invoice date, or twelve months where invoiced or settled in rupees.
- EDF for larger receipts. Companies, LLPs and firms still file the EDF for remittances above ₹10 lakh.
- Your bank's information requests. The bank can still ask for invoices, purpose codes and other details under its own procedures.
- GST and income tax. This is a FEMA reporting change only. Export of services under GST (LUT, invoices, refunds) and income-tax reporting work as before.
- Software exports. Software exports have historically had their own declaration process. If you export software, ask your bank how the deemed route applies to your receipts before you stop filing.
A simple checklist for freelancers and small IT firms
- Talk to your AD bank. Ask how it will record deemed submission for your receipts and what information it needs (invoice number, client, purpose code).
- Give complete details every time money arrives. Deemed submission depends on the bank having what it needs to credit your account.
- Keep one register of invoices and receipts: invoice date, amount, currency, date received, bank reference, and whether the EDF was filed or deemed. This also helps with the nine-month realisation rule.
- Flag receipts above ₹10 lakh (for companies, LLPs and firms) so the EDF is still filed on time.
- Chase overdue invoices well before nine months. Late realisation is still a FEMA issue.
What this means for your billing software
If you raise export invoices from an ERP or billing tool, a few small changes save a lot of manual work:
- A field per export invoice for EDF status: filed, deemed, or pending.
- An automatic flag when a single receipt crosses ₹10 lakh, if you are not a resident individual.
- An ageing report on unrealised export invoices with alerts at, say, six and eight months.
- Matching foreign inward remittances to invoices, including partial payments and bank charges.
Our GST billing software checklist covers the GST side of export invoices, and our note on GST e-invoicing for import of services covers changes on the import side.
Need export-ready billing or ERP?
Nextinera builds ERP and custom billing software with export invoicing, multi-currency receipts, realisation ageing and bank reconciliation. Book a free call to talk through your process.