RBI's EDF rule: freelancers are out, agencies are in. Do you need to file?

Short answer: if you're an individual freelancer paid by a foreign client for personal-nature work like tutoring, design or small software jobs, RBI says you don't need to file an EDF. If you invoice through a company, LLP, partnership firm or agency, you do: one EDF per month, filed with your bank within 30 days of the month's end. Sole proprietors are in a grey zone until RBI publishes its FAQs. Run your case through the EDF checker.

The freelancer relief is based on what RBI's top officials said on record at the 7 October press conference, as reported by Business Today, ET, Mint and The New Indian Express. The regulation itself hasn't been amended, and RBI's FAQs aren't out yet. We'll update this page when they are.

What the regulation says

The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, in force from 1 October 2026, brought service exports into the EDF system. Under regulation 3(2):

• An exporter of services must file an EDF with the full export value within 30 days from the end of the month in which the invoice was raised.
• A single EDF can cover all exports made in a month.
• Exporters of services other than software can file on or before the date of payment.
• The bank can extend the deadline if you give reasons.

Where to file: with your Authorised Dealer (AD) bank, the bank that receives your foreign payments. Software exporters can also file with STPI, and units in an SEZ file with the Development Commissioner.

What RBI clarified on 7 October

According to Business Today, Deputy Governor Rohit Jain said individuals “are not included with respect to the reporting requirements for the contracts of a personal nature.” Governor Sanjay Malhotra added that people “providing services as an individual outside, could be tutoring services, could be some small software etc., and getting paid for it… are not required to report.”

Malhotra also said that for exporters who are covered, a self-declaration is enough for bills up to ₹10 lakh each. The bank handles the reporting on RBI's systems, and RBI will issue FAQs to clear up the confusion.

Who files, at a glance

The other rules that matter if you file

• ₹10 lakh per invoice: for invoices up to ₹10 lakh, the bank can close the entry on your self-declaration that you've been paid. You can also submit these declarations quarterly in bulk (regulation 4).
• 9 months to get paid: export proceeds must come in within nine months of the invoice date, or 12 months if you invoice or settle in rupees. These periods were cut from 15 and 18 months by the 22 September amendment. The bank can extend them if you give reasons.
• Short payments: for invoices up to ₹10 lakh, a reduced or unpaid amount can be accepted on your own declaration (regulation 6).
• No penalties from your bank for regulatory delays: the regulation bars banks from charging you for a regulatory delay or violation (regulation 19(3)).

Getting it filed

If the checker says you need to file, start with your bank's EDF format and process. Every AD bank has to publish its policy and SOP for these transactions on its website.

For help filing EDFs, EDFfiling.in has a free checker that works one invoice at a time, a step-by-step filing guide, and a free generator that produces the EDF in RBI's layout, ready to sign and send to your bank.

This explainer isn't legal or tax advice. If you're unsure about your status, check with your AD bank or a chartered accountant.