The Japan Times - RBI eases export-declaration compliance for individual service exporters

The Reserve Bank of India (RBI) has clarified the requirements for submitting the Export Declaration Form (EDF) for exporters of services. Under the latest amendment, resident individuals will be deemed to have submitted the EDF once they provide the required payment-related information to their authorized dealer (AD) bank. The RBI issued the Foreign Exchange Management (Export and Import of Goods and Services) (Second Amendment) Regulations, 2026, through a Gazette notification dated 2 November 2026. The regulations will come into force retrospectively from 1 October 2026.

The amendment follows the RBI's earlier amendment dated 22 September, which also came into effect on 1 October. Here's what you need to know. What were earlier EDF submission requirements?The 22 September regulation mentioned that, “An exporter of services shall furnish to the specified authority a declaration in EDF specifying the amount representing the full export value of services, within 30 days from the end of month in which invoice for services has been raised.”

An exporter providing services to one or more recipients during a month could submit a single EDF covering all such exports.Exporters of services other than software could submit the EDF on or before the date of receipt of payment. What is the EDF filing rule?Under FEMA, an EDF is a document that an exporter submits to their AD bank, declaring the services exported and the corresponding payment expected from overseas clients.

The bank records the declaration in the RBI's Export Data Processing and Monitoring System (EDPMS). The transaction remains pending against the exporter's PAN until the bank receives and matches the payment with the declaration. Exporters must submit the EDF within 30 days from the end of the month in which the invoice is raised. For invoices issued in October, the submission deadline is 30 November.

What has RBI changed in latest amendment?The 2 November amendment introduces a definition of a resident individual and clarifies when an EDF will be considered submitted. The RBI has defined a resident individual as “a person resident in India who is a natural person.”

Did resident individuals need to submit EDF?The RBI has inserted a new provision: “The exporter of services shall be deemed to have submitted the EDF when such exporter, being a resident individual, provides information required in relation to the receipt of payment for such services to the Authorised Dealer for crediting the account of the exporter.” In simpler terms, individuals earning income from overseas clients, such as freelancers, YouTubers and independent professionals, will not have to submit an EDF separately if they provide the required payment-related information to their bank.

What is ₹10 lakh threshold for other service exporters?For exporters who are not resident individuals, the amendment provides the same deemed-submission facility when the inward remittance for a service does not exceed ₹10 lakh (or its equivalent in foreign currency). This means that companies and other service exporters can also benefit from simplified EDF compliance for eligible service export receipts up to ₹10 lakh.

What has changed in import reporting under IDPMS?The RBI has also amended Regulation 18(1)(d), which deals with reporting imports of services in the Import Data Processing and Monitoring System (IDPMS). IDPMS is an RBI reporting platform through which AD banks record and monitor import transactions and related payments.

The revised provision states that the AD “shall enter details of import of service in IDPMS, as furnished by the importer who is a person other than a resident individual and where the invoice or the contract value is over ₹10 lakh (or its equivalent in foreign currency), within five working days of receipt of details.” This means that AD banks must enter import-of-service details in IDPMS within five working days of receiving the information when the importer is not a resident individual, and the invoice or contract value exceeds ₹10 lakh.

However, the IDPMS reporting requirement will not apply to resident individuals or to eligible transactions of ₹10 lakh or less.

S.Ogawa--JT