A S BANKA ADVISORS

If your startup invoices customers abroad, the Export Declaration Form has run on a 30-day clock from the end of the invoice month since 1 October 2026. RBI has now eased it for smaller receipts, but the line does not sit where most finance teams will first look. It is drawn on the payment that reaches your bank, not on the invoice you raised.

The Foreign Exchange Management (Export and Import of Goods and Services) (Second Amendment) Regulations, 2026, notified by RBI on 2 November 2026 as Notification No. FEMA 23(R)/(2)/2026-RB, come into force from 1 October 2026. They change regulations 2(1), 3(2) and 18(1)(d) of the principal Regulations, and nothing else.

What stays: the EDF is still the rule

Regulation 3(2) still requires an exporter of services to declare the full export value in the EDF within 30 days from the end of the month in which the invoice is raised. Services include software. A single EDF may cover all of a month’s exports, and an exporter of services other than software may submit it on or before the date of receipt of payment (provisos (c) and (d)). The amendment adds two cases where the EDF is deemed submitted. It does not abolish the form.

Your company and you are on different sides of the line

• A resident individual (new regulation 2(1)(da): a person resident in India who is a natural person) is deemed to have submitted the EDF on giving the Authorised Dealer the information required for the receipt of payment, for crediting the exporter’s account. Proviso (a) carries no value limit.
• A person other than a resident individual gets the same treatment only if the value of the inward remittance for the service is not more than Rs 10 lakh or its foreign currency equivalent (proviso (b)).

A private limited company or an LLP is not a natural person, so it sits under proviso (b). Above Rs 10 lakh, proviso (b) is not met and the main rule applies.

The same Rs 10 lakh, measured three ways

This is where a tracker built on invoices goes wrong. The Regulations use one figure with different yardsticks:

• Inward remittance: the deemed EDF for a company (regulation 3(2), proviso (b)).
• Invoice or contract value: the bank’s IDPMS entry for import of services (regulation 18(1)(d)).
• Invoice for services: closing an EDPMS or IDPMS entry on your declaration (regulation 4(2)) and reducing export value on your declaration (regulation 6).

So a company with a Rs 12 lakh invoice paid through a single Rs 12 lakh remittance gets none of these export-side relaxations.

If you pay overseas vendors

Regulation 18(1)(d) now has the bank enter import of service in IDPMS only for an importer other than a resident individual, and only where the invoice or contract value is more than Rs 10 lakh. The bank does this within five working days of receiving the details you furnish. Regulation 18(1)(e) is unchanged, so the bank still enters inward and outward remittances for all exports and imports in EDPMS or IDPMS.

What has not moved

Realisation stays at nine months from the date of invoice for services, and twelve months where invoiced or settled in Indian Rupees (regulation 5). The bank must still be satisfied of the genuineness of the transaction before crediting your account (regulation 4(2)), and must still follow up on outstanding entries (regulation 18(1)(f)).

Your checklist

1. Record whether each exporting or importing entity is a resident individual or a person other than one.
2. Add the inward remittance value to your EDF tracker alongside the invoice value.
3. Keep the calendar running: under the main rule, the 30 days for invoices raised in October 2026 end on 30 November 2026.
4. Speak to your bank. The deeming provisos are tied to the receipt of payment, while the 30 days run from the invoice month. Confirm how it is handling invoices unpaid when that period ends, and part payments of a larger invoice.
5. If you are in a SEZ or file software EDFs through STPI, note that regulation 2(1)(f) names a different specified authority, while the new provisos speak of information given to the Authorised Dealer.
6. List service import invoices or contracts above Rs 10 lakh and furnish details to the bank.

If an EDF slips, regulation 3(2)(e) lets you ask the Authorised Dealer for more time, citing reasons for the delay.

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Source: Reserve Bank of India, Notification No. FEMA 23(R)/(2)/2026-RB, 2 November 2026, rbi.org.in. Source: Reserve Bank of India, Notification No. FEMA 23(R)/2026-RB, 13 January 2026 (amended up to 2 November 2026), rbi.org.in.

Need help navigating this? Book a quick call: talk to A S Banka Advisors Private Limited about your EDF, EDPMS and IDPMS position.