Who needs to file an EDF?
| You bill foreign clients as | File an EDF? | Basis |
|---|---|---|
| Company, LLP, partnership firm, agency | Yes, monthly | Regulation 3(2) |
| Sole proprietor (GST / IEC / current account) | Ask your bank | No exemption in the text; RBI FAQs pending |
| Individual in your own name (freelancer, tutor, creator) | Most likely not | RBI statement, 7 Oct 2026 |
| Unit in an SEZ | Yes, to the SEZ Development Commissioner | Regulation 2(1)(f) |
What counts as software?
RBI defines software as "any computer programme, database, drawing, design, audio/video signals, any information by whatever name called in or on any medium other than in or on any physical medium". So designers, video editors and architects sending files online are treated as software exporters: the EDF is due strictly within 30 days after the invoice month, and STPI is an alternative to the bank. Other services may also submit on or before the date of payment (Regulation 3(2)(b)).
Questions
Do freelancers need to file an EDF?
If you work as an individual in your own name, most likely not. On 7 October 2026 RBI said individuals providing services abroad, such as tutoring or small software work, are not required to report, and that it will publish FAQs. The Regulations' text has no exemption yet, so if your bank asks for an EDF, give one.
Do companies, LLPs and partnership firms need to file?
Yes. Any company, LLP, firm or agency that exports services must give an EDF to its bank for invoices dated on or after 1 October 2026 (Regulation 3(2)).
What about sole proprietors?
Unclear until RBI publishes its FAQs. The Regulations apply to exporters of services without a size limit, while RBI's 7 October statement covered individuals. If you trade with GST, an IEC or a business current account, ask your bank what it expects.
Is there a minimum amount?
No minimum in the Regulations. For invoices up to ₹10 lakh, the bank can close the entry later on your own declaration (Regulation 4(2)).
Do invoices before 1 October 2026 need an EDF?
No. The new rule applies to invoices dated 1 October 2026 or later, even if payment for older invoices arrives later.
Does YouTube or AdSense income need an EDF?
RBI has not said. Opinions differ on whether ad revenue is an export of services. Ask your bank, and wait for RBI's FAQs.