RBI
How do SEZ units file the EDF on SEZ Online from 1 October 2026?
What the 22 September SEZ Online webinar confirmed: all services in scope, September invoices due 30 October, SAC codes per line, cancel-and-refile, DC approval.
By Aaryan Kakani · · 6 min read
What changes for an SEZ unit on 1 October?
The legal change is Notification No. FEMA 23(R)/2026-RB dated 13 January 2026 , the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, in force from 1 October 2026 . It replaces Softex with a single Export Declaration Form for goods, services and software. The general picture is in what replaces SOFTEX on 1 October 2026 . That guide deliberately left the SEZ limb unstated. The 22 September webinar is the first detailed account of how the SEZ Online system will run it.
| Question | From 1 October 2026 |
|---|---|
| Which services are covered? | All services: IT, ITES, consultancy, engineering, architecture and similar |
| How is an error fixed? | Cancel the EDF and refile; no editing |
| How is a credit note handled? | Cancel the original EDF, refile at the revised value |
| What invoice detail is reported? | Invoice line items, each with a GST SAC code |
| Does paper go to the DC or bank? | No, the data flows electronically by API |
| Who approves? | The SEZ DC/ADC office, not the AD bank |
| How often do I file? | Monthly, on timelines similar to Softex |
Which exports need an EDF?
The scope is wider than Softex in one direction and narrower than people fear in another. The webinar tied the obligation to actual foreign currency realisation through an AD bank .
| Transaction | EDF needed? |
|---|---|
| Export of goods | Yes |
| Software, IT and ITES services | Yes, replaces Softex |
| Consultancy, engineering, architectural and similar services | Yes, newly in scope |
| Intercompany charge settled in foreign currency through an AD bank | Yes |
| Pure book entry or reimbursement, no realisation through an AD bank | May be excluded, pending written clarification |
| Foreign currency transaction within India where the AD bank asks for a departmental document | May apply, RBI/DGFT clarity awaited |
| A month with no export invoices and no realisations | No, a nil EDF is not required |
The two "pending" rows are the ones to plan around. Treat a reimbursement or book-entry settlement as not yet decided, not as excluded. Keep the supporting invoices ready so you can file within the month if the written clarification brings them in.
When is my first EDF due?
30 October 2026, for September 2026 invoices. This is the date most units will get wrong. The invoices were raised while Softex still existed, but the filing falls due after it is gone, so they are filed as an EDF.
| Invoices raised in | Form | File by |
|---|---|---|
| August 2026 or earlier, filed on time | Softex | Already due |
| August 2026 or earlier, filed late after 1 Oct | EDF | Immediately |
| September 2026 | EDF | 30 October 2026 |
| October 2026 onward | EDF | Monthly, on the Softex-style timeline |
What must each EDF carry?
The EDF is reported at invoice line-item level , and the webinar said the data broadly mirrors what units already report in the SCRF. Five rules came out of it.
- A GST SAC code on every service line. Invoices without SAC codes must be updated from October 2026.
- Clubbing is allowed. One EDF can carry several invoices, clients, currencies and SAC codes, provided each line item is detailed.
- Exchange rates auto-fill from CBIC where CBIC publishes one. For a currency CBIC does not cover, you enter the rate by hand. Keep the source of that rate on file.
- Invoice attachments up to 10 MB , as a merged PDF, ZIP or Excel file.
- Bulk annexures for large volumes. A unit raising hundreds of invoices a month can upload them as an annexure, not key each one in.
The field-by-field detail is in which fields an export invoice must carry . The EDF template itself is not yet published (section 8).
How do I correct an EDF or apply a credit note?
Cancel and refile. There is no edit. The webinar was explicit on both points: an EDF cannot be amended once filed, and a credit note cannot be filed as a separate EDF.
- Identify the EDF that carries the invoice the credit note reduces.
- Cancel that EDF in SEZ Online.
- Refile it with the invoice at its revised value. Every other line on the original EDF is refiled too, because the cancellation removes the whole form.
- The refiled EDF goes back to the DC office for approval and then to the bank, so the bank's realisation figure follows the revised value.
Who approves it, and what reaches my bank?
The SEZ DC or ADC office approves. The webinar said so directly, and flagged that some bank presentations had said the AD bank would. For an SEZ unit it will not.
- The unit files the EDF in SEZ Online.
- The DC/ADC office approves it.
- The approved EDF is transmitted in real time to RBI's new system (called UFI at the webinar) and to the unit's AD bank.
- The AD bank marks realisation against it when the foreign currency arrives.
Nothing goes on paper. No EDF printout needs to be handed to the DC office or the bank. If your bank's branch asks for one, the webinar position is that the data already reached it by API. Ask the branch to look it up.
Realisation still has to happen, and it still gets tracked. How the bank-side record closes is covered in how EDPMS reporting works .
What happens to Softex filings still pending?
- Pending Softex cancellations and certifications will still be processed after 1 October 2026.
- A Softex not yet filed by 1 October cannot be filed as a Softex. It is filed late, as an EDF.
- APR, monthly reports and SCRF continue unchanged for now.
The practical deadline is therefore 30 September 2026 for anything you want filed as a Softex. After that, the late filing has to meet EDF rules, including SAC codes on every line.
What did the webinar leave open?
Several cases were deferred to written clarification. If your unit falls into one, do not build a process around a guess.
| Open question | Status on 25 Sep 2026 |
|---|---|
| Services rendered through a branch office | Written clarification promised |
| IFSC units | Written clarification promised |
| Onsite services delivered abroad | Written clarification promised |
| Nepal and Bhutan billing in INR | Written clarification promised |
| Pure book entries and reimbursements | May be excluded, pending clarification |
| Foreign currency transactions within India | RBI/DGFT clarity awaited |
| EDF manual and Excel template | Promised online within 2 to 3 days of 22 Sep |
| Follow-up webinar | Promised before 1 October 2026 |
What should I do before the first filing?
- By 30 September: file every Softex you can still file as a Softex.
- Now: check that your invoice template carries a GST SAC code on every service line. Add it before the October invoicing run.
- Now: list every service line you bill abroad, including consultancy and engineering, and confirm each will be on an EDF.
- Before 30 October: update September invoices that lack SAC codes, then file them as an EDF.
- Decide how you club invoices. Separate clients with frequent credit notes into their own EDFs (section 5).
- Tell your bank that EDF data will arrive by API and that no printout will follow.
Frequently asked questions
When does an SEZ unit start filing the EDF instead of Softex?
From 1 October 2026. That is the date the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB dated 13 January 2026, come into force, and the SEZ Online webinar held on 22 September 2026 confirmed that the online EDF for goods and all service exports goes live in SEZ Online on the same date. Softex is fully replaced. Any Softex filed late after 1 October 2026 has to be filed as an EDF instead.
What is the deadline for filing September 2026 invoices?
30 October 2026, and in EDF format, not Softex. The 22 September 2026 webinar stated that September invoices must be filed as an EDF by 30 October, and that monthly filing timelines otherwise stay similar to the Softex timelines units already work to.
Do non-IT service exports need an EDF?
Yes. The webinar stated that EDF filing becomes mandatory for all service exports from SEZ units, including non-IT and ITES services such as consultancy, engineering and architectural services. From 1 October 2026 every one of them is reported on an EDF.
Do I need to file a nil EDF in a month with no exports?
No. The webinar confirmed that a unit does not need to file a nil EDF for a period with no export invoices and no foreign currency realisations.
How do I correct an EDF or apply a credit note?
By cancelling the original EDF and filing a fresh one. The webinar stated that an EDF cannot be edited after filing and that a credit note cannot be filed separately. The unit cancels the original EDF and refiles it with the revised invoice values.
Who approves the EDF for an SEZ unit, the DC or the bank?
The SEZ Development Commissioner or Assistant Development Commissioner office. The webinar stated this explicitly, noting that some bank presentations had suggested otherwise. Once the DC approves the EDF, it is sent electronically to the RBI system and to the unit's AD bank for realisation. No printout goes to the DC office or the bank.
Will every EDF you file be matched to the money that paid it?
Seasaw matches every inward remittance to the invoice and declaration it pays, flags short receipts before your bank does, and shows which entries are still open. That record is what the monthly EDF filing is built from.
Update history
- First published.