## RBI's November EDF amendment. What changed for freelancers

On 2 November 2026 the RBI notified a second amendment to the export regulations that took effect on 1 October. The short version is that most freelancers paid by foreign clients no longer file a separate Export Declaration Form. Giving your bank the details it needs to credit the payment now counts as the filing.

This guide covers what the amendment says, who it covers, what it does not change, and the parts that are still unclear.

## What the EDF was supposed to be

From 1 October 2026, FEMA 23(R)/2026-RB brought goods, software and services under one [Export Declaration Form](https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx). Service exporters, who had never filed anything with the RBI, were to file a monthly EDF within 30 days of the end of each invoice month. SOFTEX was retired. The [EDF guide](/blogs/edf-guide-freelancers) covers that version of the rule.

Five weeks after the rule took effect, the RBI changed who has to file.

## What the amendment says

- **Defines a resident individual:** a person resident in India who is a natural person. That is you, not your company.
- **Deems the EDF filed for individuals:** a service exporter who is a resident individual is treated as having submitted the EDF when they give their bank the information required for receiving the payment and crediting their account. There is no amount limit.
- **Deems the EDF filed for small payments to entities:** a service exporter that is not an individual gets the same treatment when the inward remittance for the service is ₹10 lakh or less, or the equivalent in foreign currency.

On the import side, banks now enter service imports into IDPMS only when the importer is not an individual and the invoice or contract is above ₹10 lakh.

The amendment is effective from 1 October 2026, the same day the original rule started. So the monthly EDF for October that many freelancers were preparing for 30 November is not due from individuals at all.

## Who files what now

| You are | Payment size | What you do |
| --- | --- | --- |
| Individual freelancer, creator or consultant | Any | Nothing separate. The details you give your bank when the payment lands are the filing |
| Sole proprietorship | Any | Most likely the same as an individual, since a proprietorship is legally its owner. Confirm with your bank how they treat your current account |
| Company, LLP or partnership firm | ₹10 lakh or less per remittance | Nothing separate. Same deemed filing |
| Company, LLP or partnership firm | Above ₹10 lakh in a single remittance | Full EDF within 30 days of the end of the invoice month |
| Software exporter, any form | As above | Same rules. SOFTEX stays retired, the EDF replaces it where one is still needed |
| Anyone paying a foreign vendor for services | Above ₹10 lakh, non-individuals only | Bank enters it in IDPMS. Form A2 and tax forms still apply |

The ₹10 lakh test is on the inward remittance, not on your annual turnover. A firm receiving ₹8 lakh a month from one client never files. The same firm receiving one ₹12 lakh payment files for that payment.

## What "deemed filed" means in practice

The regulation does not say you file nothing. It says the information your bank already collects to credit a foreign payment is the filing. That information is what a bank asks for today.

- **Purpose code:** the RBI code for the kind of service. P0802 for software consultancy, P1007 for advertising, and so on.
- **Invoice or reference:** the invoice number, date and amount the payment relates to.
- **Declaration:** a line confirming the payment is for export of services, usually a tick box or a one-page form from the bank.
- **SAC code:** some banks ask for it alongside the purpose code.

If your bank or platform already asks for these, you are already compliant. If a payment is credited without them, the bank has not done its part, and that is the thing to chase.

Keep every invoice and every FIRA anyway. The amendment removed a form, not the record.

## What has not changed

- **The 9-month realisation period:** service export proceeds still have to arrive within 9 months of the invoice date, or 12 months if you invoice in rupees. That was set by the 22 September amendment and the November one leaves it alone.
- **FIRA:** your bank still issues a Foreign Inward Remittance Advice for each payment. It is still the document your CA, GST refund and AIS reconciliation run on.
- **GST:** exports of services are still zero-rated, the LUT still has to be filed if you are registered, and the ₹20 lakh registration threshold is unchanged.
- **Tax reporting:** every inward remittance still appears in your AIS. Advance tax still runs on it.
- **The caution list:** entities with open EDPMS entries above ₹10 lakh can still end up on it if payments do not arrive.

## Four things that are still unclear

- **Proprietorships:** the regulation defines a resident individual as a natural person and does not mention proprietorships. A proprietorship is its owner, so the sensible reading is that individual treatment applies. Banks run proprietorship current accounts on different systems from savings accounts and may not have updated them. Ask yours, and ask in writing.
- **Instalments:** a ₹24 lakh invoice paid in three ₹8 lakh instalments is three remittances under ₹10 lakh. Whether that counts as three deemed filings or one EDF is not settled. Do not plan around it.
- **What "information required" means:** each bank decides what it asks for. Expect a short declaration form at most banks and some variation for a few months.
- **Platforms and PA-CB rails:** when a payment comes through a payment aggregator rather than a direct wire to your branch, the details are given to the platform and its partner bank. FEDAI issued guidance on this in October. Ask your platform in writing how it handles the deemed filing.

### The timeline so far

| Date | What happened |
| --- | --- |
| 13 January 2026 | FEMA 23(R)/2026-RB notified. One EDF for goods, software and services from 1 October |
| 22 September 2026 | First amendment. Realisation period cut to 9 months, 12 for rupee invoices |
| 1 October 2026 | Regulations take effect. SOFTEX retired |
| 2 November 2026 | Second amendment. Deemed filing for individuals at any amount, and for entities up to ₹10 lakh. Effective 1 October |
| 30 November 2026 | First full EDF due, but only from entities with a single October remittance above ₹10 lakh |

### What to do

1. **If you are an individual:** stop preparing a monthly EDF. Check that your bank asks for a purpose code and invoice reference on each incoming payment. If it does not, ask how they are recording the deemed filing.
1. **If you run a proprietorship:** email your branch one question. "Under FEMA 23(R)/(2)/2026-RB, are you treating my proprietorship current account as a resident individual for EDF purposes?" Keep the reply.
1. **If you run a company, LLP or firm:** list every single inward remittance above ₹10 lakh since 1 October. Those still need an EDF by 30 November for October invoices. Everything else needs nothing separate.
1. **Everyone:** keep filing GST and LUT as before, keep the FIRAs, and tell your CA the rule changed. Most will not have seen it yet.

## How DashX helps

[DashX](/) operates through RBI-authorised AD Category I banks (JP Morgan and HDFC) and PA-CB licensed partners. Every payment carries a purpose code and an invoice reference at the point of receipt, and the FIRA is generated with the payment. For an individual freelancer that is the information the amendment says counts as the filing, captured once, at the moment the money moves.

This article explains the regulation. Whether your bank has updated its process, and how your structure is treated, is a conversation with your bank and your CA.

Get documented international payments without the headache. [Try DashX](https://gateway.dashx.xyz/login?redirect=%2F).

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