Export · getting paid
Exporting services from 1 October 2026: EDF and nine months
From 1 October 2026, export earnings must be realised within nine months of the invoice date, and an EDF may be due 30 days after each invoice month ends.
Checked against official sources on 13 October 2026. General information, not tax or legal advice; for your own situation, ask your CA or advocate.
From the Export Desk, chapter 8Look inside the Export Desk
What changed on 1 October 2026?
New export rules came into force: the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. The Reserve Bank of India notified them on 13 January 2026 as FEMA 23(R)/2026-RB, and amended them on 22 September 2026, before they took effect. The RBI publishes the text, as amended, on rbi.org.in (source 1, source 2).
Two parts of the regulations matter to anyone who invoices clients abroad for a service (source 1):
- A deadline for the money: nine months from the invoice date (regulation 5(1)).
- A declaration to your bank: the Export Declaration Form, or EDF, within 30 days of the end of the invoice month (regulation 3(2)).
The amendment of 22 September 2026 shortened the realisation period the regulations first set (source 2). Articles and calculators written before then may give a longer period, so check the date of anything you read.
How long do you have to get paid?
Nine months from the date of the invoice. Regulation 5(1) says the full value of exported services must be realised and repatriated within nine months “from the date of invoice”, and within twelve months when the export is invoiced or settled in Indian rupees. Your AD bank, the authorised dealer bank that handles your export payments, may extend the period if you ask and give your reasons (source 1).
The clock starts on the invoice date: not on the due date in your agreement, and not on the day the work ended (source 1). This guide and the free export invoice check count to the same date nine months later, or to the last day of that month when the date doesn’t exist in it:
| Invoice dated | Money in India by |
|---|---|
| 15 October 2026 | 15 July 2027 |
| 30 November 2026 | 30 August 2027 |
| 31 December 2026 | 30 September 2027 |
| 31 May 2027 | 29 February 2028 |
| 15 March 2027, invoiced in rupees | 15 March 2028 |
Invoicing a client abroad in rupees raises a GST question first. Under GST, a service counts as an export only if it is paid for in convertible foreign exchange, or in rupees where the RBI permits (source 3). Ask your CA before you invoice in rupees.
When an invoice gets close to its date, ask your bank how it counts the period, and ask before the date rather than after it.
What is the EDF, and when is it due?
The Export Declaration Form is a declaration of the full export value of your services, made to what the regulations call the specified authority. For services other than software, that is your AD bank; for software, it is an AD bank or the Software Technology Parks of India (STPI) (source 1).
Regulation 3(2) sets four rules for it (source 1):
- When: within 30 days from the end of the month in which the invoice was raised.
- How many: one EDF can cover all of a month’s exports, to one client or to several.
- Another option, for services other than software: the EDF may be submitted on or before the date the payment is received.
- If you’re late: your bank may give you more time, if you ask and explain the delay.
For the rest of this financial year, 30 days after the end of each month falls on these dates. They apply only if your bank says you file.
| Invoices dated in | EDF by |
|---|---|
| October 2026 | 30 November 2026 |
| November 2026 | 30 December 2026 |
| December 2026 | 30 January 2027 |
| January 2027 | 2 March 2027 |
| February 2027 | 30 March 2027 |
| March 2027 | 30 April 2027 |
January’s date falls in March because February is short.
Do freelancers have to file an EDF?
Regulation 3(2) applies to “an exporter of services” (source 1). Since the regulations came into force, the RBI has spoken about individuals in public, as reported:
- 7 October 2026. Business Today reported the RBI’s Deputy Governor, Rohit Jain, as saying individuals are “not included” in the reporting requirements “for the contracts of a personal nature”. The Governor, Sanjay Malhotra, said individuals providing services abroad need not report, giving small software work as an example, and the RBI said it would issue FAQs (source 4).
- 8 October 2026. StudyCafe reported that individuals providing services to overseas clients “will not be required to report under the new EDF rules”, and that detailed FAQs were expected (source 5). Inc42 reported the promise of FAQs too, and listed what they would need to settle, including how the remarks apply to different freelance arrangements (source 6).
- 12 October 2026. FAQs promised; none published as at 12 October 2026. The RBI’s FAQ page listed nothing on the EDF or the 2026 regulations that day (source 7).
These are reports of remarks, not a circular or an amendment. None of them says how the remarks apply to a freelancer registered for GST, a sole proprietor trading under a business name, a partnership or a small studio (sources 4, 5 and 6).
What should you do this month?
- Write to your bank. Email the AD bank that receives your export payments. Ask whether you file an EDF, how it wants it (a portal, a form or an email) and from which invoice month. If your clients pay you through a payment platform, ask whether that changes the answer.
- List October’s export invoices. For each one: the number, date, client, country, currency and amount. One EDF can cover the whole month (source 1), so this list is most of the work.
- If your bank says you file, file October’s EDF by 30 November 2026. After that, file each month’s within 30 days of the month’s end (source 1).
- Put each invoice’s nine-month date in your calendar, with a reminder a month before it. If a client will be late, ask your bank for more time before the date passes (source 1).
- Watch for the RBI’s FAQs on its FAQ page. When they appear, this guide will change, and the change will be listed at the end.
What does this mean for an invoice dated 15 October 2026?
Say you invoice a client in Germany, in euros, on 15 October 2026, under your LUT. If your bank says you file, the EDF for that invoice is due by 30 November 2026, and the money must be in India by 15 July 2027 (source 1). Because you export under an LUT, GST adds a third date (source 8):
| By | What falls due, and why |
|---|---|
| 30 November 2026 | The EDF, if your bank says you file: 30 days after the end of October, under FEMA regulation 3(2). |
| 15 July 2027 | The money, in India: nine months from the invoice date, under FEMA regulation 5(1). |
| About 30 October 2027 | The IGST, if the money still hasn’t arrived: one year and 15 days on, under CGST rule 96A. Confirm the exact date with your CA. |
The free export invoice check works out the first two dates for any invoice date you type.
How does this sit beside the GST clock?
If you export under an LUT, GST runs a clock of its own. Under rule 96A of the CGST Rules, as amended in July 2024, if the money for an exported service hasn’t arrived within one year of the invoice date, or within the FEMA period if that is later, the IGST falls due 15 days after that period ends, with interest (source 8). With FEMA at nine months, the year is the later of the two, unless your bank has extended the FEMA period. Ask your CA once to confirm how the date falls for your invoices.
The LUT itself, and renewing it for 2027-28, are in the LUT guide. What the invoice itself must say is in the export invoice guide.
What about invoices up to ₹10 lakh?
The regulations make small invoices simpler. For an invoice of up to ₹10 lakh, its entry in the banks’ export monitoring system (EDPMS) may be closed on your own declaration, and you may give your bank one declaration a quarter to close such entries in bulk. If a client pays less than an invoice of up to ₹10 lakh, or doesn’t pay it at all, your bank may also accept the shortfall on your declaration (source 1). The limit is the value of each invoice, not a yearly total.
From the kit. In the Export Desk, chapter 8 of the guide sets the two clocks side by side for each invoice, and the workbook’s EDF list sheet gathers each month’s invoices, ready for the bank.
Questions to ask your bank and your CA
Your bank
- I’m a freelancer registered for GST. Do I file an EDF? If so, how do you want it, and from which invoice month?
- My clients pay me through a payment platform. Does the platform report anything for me, or do I still file?
- If a client pays late, how do I ask you for more time to bring the money in, and what do you need from me?
- Do my invoices dated before 1 October 2026 follow the old rules or the new ones?
Your CA
- Where does the rule 96A date fall for my invoices, and what happens to my LUT if a client hasn’t paid by then?
- A client abroad has asked to be invoiced in rupees. Is that still an export for GST?
Sources
- Reserve Bank of India. Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB, 13 January 2026, as amended up to 22 September 2026. Regulations 3(2), 4, 5(1) and 6, and the definition of specified authority. Primary source. Read on 12 October 2026.
- Reserve Bank of India. Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(1)/2026-RB, 22 September 2026. Primary source. Read on 12 October 2026.
- Central Board of Indirect Taxes and Customs. Circular No. 202/14/2023-GST, 27 October 2023, quoting the five conditions of an export of services in section 2(6) of the IGST Act. Primary source. Read on 12 October 2026.
- Business Today. RBI clears the air on new forex reporting rules: Framework does not apply to individuals, 7 October 2026. Press report. Read on 12 October 2026.
- StudyCafe. RBI Eases Foreign Exchange Compliance for Small Exporters and Freelancers, 8 October 2026. Press report. Read on 12 October 2026.
- Inc42. New FEMA Rules Explained: What Freelancers, Creators, And SaaS Startups Need To Know, 8 October 2026. Press report. Read on 12 October 2026.
- Reserve Bank of India. Frequently Asked Questions, the RBI’s index of FAQs; no entry on the EDF or the 2026 regulations, and the newest entry dated 1 October 2026. Primary source. Read on 12 October 2026.
- Central Board of Indirect Taxes and Customs. Rule 96A, Export of goods or services under bond or Letter of Undertaking, CGST Rules, 2017, the CBIC’s own text, with sub-rule (1)(b) as substituted by Notification No. 12/2024-Central Tax of 10 July 2024: the tax due, with interest, 15 days after one year from the invoice date, or after the FEMA period with any extension if that is later. Primary source. Read on 13 October 2026.
What changed in this guide
- 13 October 2026. Rule 96A is now cited from the CBIC’s own text of the CGST Rules, in place of two secondary sources; the date it gives is unchanged. The summary under the title now says what regulation 3(2) says: an EDF may be due for each invoice month, within 30 days of its end. The worked example now follows an invoice dated 15 October 2026, the date of the specimen invoice used across this site, so its dates move by one day.
- 12 October 2026. Written, and checked against the sources above. The RBI’s FAQs on the EDF had not been published; when they are, this guide will be updated and the change listed here.