Since 1 October 2026, banks have started asking people paid from abroad for an EDF, an Export Declaration Form. Some ask before they will credit a payment. Some send an SMS. Some branches have never heard of it. Meanwhile the news says individuals are exempt, and the comment sections underneath say the opposite.
Both camps are quoting something real. The written rule covers “an exporter of services” with no exemption for individuals and no minimum amount. RBI's top officials then said on the record that individuals are not covered, and promised an FAQ. This page sets out exactly what each says, what your bank can and cannot ask of you, and what to do while the two disagree.
What the rule says
The rule is the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, notified on 13 January 2026, amended on 22 September 2026, and in force from 1 October 2026. It replaced the old export regulations, and for the first time it puts services on the same declaration footing as goods. Regulation 3(2) is the line that matters:
“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.”
Read closely, that gives you four working rules:
- The clock runs from the invoice month, not the payment. An invoice raised on 10 October is declared by 30 November, whether or not the client has paid.
- One form can cover the month. If you invoiced three clients in October, a single EDF may cover all three.
- Services other than software may file early, on or before the day the payment arrives.
- Late is not fatal. Your bank may extend the deadline “on a request from the exporter citing reasons for delay”.
Does it apply to you? The text and the press conference disagree
The written rule: “an exporter of services”. The regulations do not use the words individual, freelancer, creator or personal, and they set no minimum amount. On the text alone, a freelancer invoicing a foreign client is an exporter of services.
What RBI said on 7 October 2026. Asked at the post-policy press conference whether “smaller freelancers or content creators” really had to fill the form, the Deputy Governor answered, in RBI's own edited transcript:
“…the individuals are not included with respect to the reporting requirements for the contracts of a personal nature. So, there seems to be some misunderstanding on the reporting obligations, which we will clarify shortly through an FAQ.”
The Governor added that individuals, “irrespective of the amount, are not required to be reported”, and gave as examples someone “providing … services as an individual outside, could be tutoring services, could be some small software, etc., and getting paid for it”.
Where that leaves you. A statement at a press conference is not an amendment, a circular or an FAQ. “Individual” and “contracts of a personal nature” are not defined anywhere in writing, so nobody can yet say whether a freelancer with a business client, a sole proprietor, a GST-registered consultant or a creator paid ad revenue falls inside them. The examples point towards small individual earners. Until RBI writes it down, a bank that asks you for an EDF is applying the rule as it is written, and arguing the press conference at the counter is unlikely to get your payment released.
The Rs. 10 lakh rule is about proof, not about filing
You will see “no EDF under Rs. 10 lakh” repeated everywhere. That is not what the rule says. The Rs. 10 lakh figure appears in two provisos, and both are about closing the export entry once the money has come in:
- For an invoice of up to Rs. 10 lakh, your bank may close the entry “based on a declaration from the exporter” that the payment has been realised, and you may give those declarations quarterly for bulk closure.
- On the same per-invoice basis, a shortfall or non-payment can be accepted on your own declaration.
The limit is per invoice — the Governor stressed “per bill, not annually” — and the duty to file the EDF has no minimum at all. What the proviso saves you is paperwork proving payment, not the declaration itself.
What your bank can ask for, and what it has to publish
You do not log in to anything at RBI. The bank does the reporting: it must enter your EDF in RBI's export monitoring system (EDPMS) within five working days, record the payments against it, and mark the entry off once it is satisfied the money has arrived. The Governor put it plainly on 7 October: individual exporters “have to only provide this information to the ADs or the banks.”
Two parts of the regulations explain what you are seeing at the branch:
- Why a credit can be held. A bank may credit an export receipt “only after having satisfied itself of the genuineness of the transaction”. That is the written basis for a bank sitting on a payment until it has papers.
- Why every bank does it differently. RBI did not prescribe a channel, a document list or a fee. Each bank must have its own policy listing the documents, timelines and charges for each process, keep its charges “reasonable and proportional to the services rendered”, run an escalation route, and publish the main features of the policy on its website.
So the most useful question to ask your bank is not “do I have to?” but “where is your published EDF policy?”. It tells you the channel, the documents and the charge, and it is the thing to escalate against if a branch invents its own rules.
Paid through PayPal, Wise, Upwork or a rupee transfer
The EDF is tied to the invoice month. Nothing in the regulation turns on how the money travelled, and an export settled in rupees is expressly inside it. So a payment that reaches you as an ordinary domestic transfer does not, on the text, take you out of the rule.
What changes is who supplies the paperwork. RBI requires a licensed cross-border payment aggregator to give your bank the documents it needs to close your export entry. It does not file your EDF for you. Which bank counts as yours when the platform's partner bank receives the dollars and you receive rupees is not answered in any official text we have read — and bank staff telling you “rupee credits need no EDF” are describing their own practice, not the rule.
If the bank wants papers to match a payment, the useful set is the invoice, the platform's statement for that payment and the bank's credit advice. Which of those is a FIRC, a FIRA or neither has its own page.
Know your monthThe EDF is counted in invoice months. HourSlip keeps each foreign invoice with its date, currency, client country and payment, so the list your bank asks for is already sorted when it asks.The money still has to arrive in 9 months
The same regulations set how long a client has to pay: 9 months from the invoice date, or 12 months if the export is invoiced or settled in rupees. The January text said 15 months; the September amendment cut it back before the rule took effect, so any page quoting 15 is out of date.
If a client pays late, your bank can extend the period, or accept a smaller or nil amount, on a request that gives reasons. Left unpaid for more than a year past the due date, further exports are allowed only against full advance payment or a letter of credit.
SOFTEX is gone, and you still do not need an IEC
RBI's January circular superseded the SOFTEX circulars from 1 October 2026. Software exports now use the same EDF, filed with your bank or through STPI, which remains an option for software.
An Importer-Exporter Code is still not needed to export services. DGFT's own page says “for services exports however, IEC shall be not be necessary except when the service provider is taking benefits under the Foreign Trade Policy.” A bank may still ask for one in its own forms; that is its policy, not the rule.
What to do before 30 November
- List October's export invoices by date, client, country, currency and amount. That list is what any EDF is built from, whichever way RBI's FAQ lands.
- Ask your bank for its published EDF policy before it asks you for anything. Note the channel, the documents and the charge.
- If your bank asks, file. One EDF for the month is allowed. For invoices up to Rs. 10 lakh each, ask about the self-declaration route for closing them.
- Keep the payment trail for every invoice: the platform statement, the bank credit advice and the conversion. You will need it whatever the FAQ says.
- Watch for RBI's FAQ. If it confirms that individuals are out, most of this becomes record-keeping. If it narrows the exemption, you will already be ready.
The EDF sits alongside your GST position, not instead of it. If you are not sure whether exporting services means you must register for GST, below Rs. 20 lakh it does not.