RBI
Which service exports need an EDF, and which are excluded?
Consultancy, engineering and architecture join IT on the EDF from 1 October 2026. The realisation test for intercompany charges, reimbursements and nil months.
By Aaryan Kakani · · 3 min read
Which services are now in scope?
Under Notification No. FEMA 23(R)/2026-RB dated 13 January 2026 , a single Export Declaration Form covers goods, services and software from 1 October 2026 . For SEZ units the webinar made the services limb concrete:
| Service exported | EDF from 1 October 2026? |
|---|---|
| Software development and IT services | Yes (replaces Softex) |
| ITES, such as BPO and back-office work | Yes |
| Management and business consultancy | Yes |
| Engineering services | Yes |
| Architectural services | Yes |
| Other similar professional services | Yes |
What decides whether a transaction needs an EDF?
The webinar said an EDF is required only where actual foreign currency realisation through AD banks occurs . That gives a working test for any transaction:
- Is there an export invoice for a service? If not, there is nothing to declare.
- Will foreign currency be realised through your AD bank? If yes, file an EDF.
- Is it settled only by book entry, or is it a pass-through reimbursement? Then it may be excluded, but that is pending clarification (section 3).
- Is the foreign currency coming from inside India? Then the position is open (section 4).
How the bank records realisation against a declaration is in FIRC and BRC: the realisation documents .
Do intercompany charges and reimbursements need one?
| Transaction | Position on 25 Sep 2026 |
|---|---|
| Service fee to a foreign group company, paid in foreign currency through the AD bank | EDF required |
| Service fee to a group company settled only by book entry or netting | May be excluded, pending clarification |
| Reimbursement of costs incurred for a foreign client or parent | May be excluded, pending clarification |
What about foreign currency received inside India?
The webinar said the EDF may apply to foreign currency transactions within India where the AD bank requires a departmental document before it will credit the money. Further clarity from RBI or DGFT is expected.
- Ask your AD bank what document it currently needs to credit such a receipt.
- If it names a departmental document, expect that to become an EDF, and ask your DC office how to file it.
- Do not stop receiving or crediting the money while you wait. The open question is the paperwork, not the transaction.
Do I file anything in a month with no exports?
No EDF. A unit need not file a nil EDF for a period with no export invoices and no foreign currency realisations. The webinar said separately that the APR, monthly reports and SCRF continue unchanged for now, so those still follow their own rules in a quiet month.
Which cases are still waiting for an answer?
Four arrangements were set aside for written clarification. If your unit bills this way, do not settle on a filing approach until the clarification is out. A follow-up webinar was promised before 1 October 2026.
| Arrangement | What to have ready |
|---|---|
| Services delivered through a branch office | Which entity invoices, and which receives the money |
| IFSC units | Your unit's approval and the currency of billing |
| Onsite services delivered abroad | Where staff worked, the contract and the invoice split |
| Nepal and Bhutan clients billed in INR | Invoices, and how payment reached your account |
Everything else the webinar settled, including the approval route and the 30 October deadline, is in how SEZ units file the EDF on SEZ Online .
Frequently asked questions
Do consultancy and engineering exports need an EDF?
Yes. At the SEZ Online webinar on implementing the EDF, held on 22 September 2026, units were told that EDF filing becomes mandatory from 1 October 2026 for all service exports, including non-IT and ITES services such as consultancy, engineering, architectural and similar services.
Do intercompany charges need an EDF?
Where the charge is actually realised in foreign currency through an AD bank, yes. The webinar tied the EDF requirement to actual foreign currency realisation through an AD bank. Pure book entries and reimbursements with no such realisation may be excluded, but that was stated as pending clarification, not settled.
Is a nil EDF required for a month with no exports?
No. The webinar confirmed that units need not file a nil EDF for periods with no export invoices or foreign currency realisations.
Does an EDF apply to foreign currency received from a customer in India?
Possibly. The webinar said the EDF may apply to foreign currency transactions within India where the AD bank requires a departmental document, and that further clarity from RBI or DGFT is expected. Treat it as open.
Do you know which receipts were realised through your AD bank?
Seasaw lists every inward remittance against the invoice it pays, so the set of transactions that need an EDF is a filter, not a month-end hunt through bank statements.
Update history
- First published.