The Reserve Bank of India’s new foreign exchange rules have introduced an Export Declaration Form (EDF) filing requirement for service exporters, drawing criticism from freelancers, consultants and small businesses that receive payments from overseas clients.

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The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 came into effect on October 1. The framework covers a wide range of service providers, including freelancers, consultants, content creators, agencies, software professionals, BPOs, online educators and businesses serving overseas entities.

Under the new requirement, service exporters must submit an EDF declaring the full value of their exports to the Authorised Dealer (AD) bank through which the foreign payment is received. The filing must generally be completed within 30 days from the end of the month in which the service invoice was raised.

For example, an invoice issued in October 2026 would have an EDF filing deadline of November 30, 2026. For services other than software, the designated AD bank enters the declaration into the Export Data Processing and Monitoring System (EDPMS).

The RBI rules also generally require the full export value of services to be realised and repatriated within nine months from the invoice date.

The requirement has sparked concerns about additional paperwork and coordination with banks. Capitalmind CEO Deepak Shenoy criticised the compliance burden, while JauntLabs founder Amit Ranjan argued that the rule could create additional friction for freelancers, consultants and small technology firms.

The debate centres on whether tighter reporting requirements will improve monitoring of service exports or add unnecessary compliance costs for smaller exporters.