Indian IT companies, consulting firms, and other service exporters must now adhere to a new, tighter deadline for submitting their Export Declaration Forms (EDF). Under the Reserve Bank of India's (RBI) revised Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, which came into effect on October 1, 2026, companies must file an EDF within 30 days from the end of the month in which an invoice for services is raised.
This regulatory update consolidates rules governing cross-border transactions and expands the responsibilities of authorised dealer (AD) banks in managing export and import compliance. The change emphasizes the need for streamlined coordination between billing, treasury, and compliance teams within service-providing organizations.
Key Changes for Service Exporters
The new framework extends the EDF requirement, previously more common for goods, to the export of services. While a single consolidated declaration can cover multiple invoices issued during a month, even to different overseas customers, detailed invoice-wise information is mandatory. This includes the customer's name, country, invoice number and date, currency, value, and the nature of services provided.
For example, all invoices raised in October 2026 would need to be covered by a consolidated EDF filed by November 30, 2026. However, if payment for an invoice is received before this standard deadline, the declaration must be submitted on or before the payment receipt date. This necessitates robust internal processes for tracking invoice dates and incoming payments to ensure timely compliance.
Software Exports and Realization Deadlines
Software continues to be classified as a service under these updated regulations. The existing SOFTEX process is expected to remain in use where applicable, though specific filing procedures may vary. Exporters in the Domestic Tariff Area might submit declarations through their AD bank or the Software Technology Parks of India (STPI), while those in Special Economic Zones may work with the Development Commissioner.
The revised framework also adjusts the deadline for realizing and repatriating export proceeds. For services, including software exports, proceeds must be realized within nine months from the invoice date. Exports invoiced or settled in Indian rupees are granted a longer 12-month period. Should an exporter be unable to realize proceeds within the stipulated timeframe, an extension can be sought from their AD bank, supported by valid reasons and documentation.
Businesses are advised to promptly update their compliance calendars, align their billing and treasury departments, and obtain the latest procedural guidelines and document checklists from their respective AD banks to effectively navigate these new requirements.