RBI Eases Services Reporting: No Separate EDF for Individuals, ₹10 Lakh Relief for Others

RBI has relaxed two services-related reporting obligations introduced on 1 October 2026: the Export Declaration Form (EDF) for service exports and the Import Data Processing and Monitoring System (IDPMS) entry for service imports. Resident individuals are taken out of both; other persons get relief up to ₹10 lakh per transaction.

Item	Detail
Notification	FEMA 23(R)/(2)/2026-RB — FEM (Export and Import of Goods and Services) (Second Amendment) Regulations, 2026
Dated / Gazette	2 November 2026, Gazette Extraordinary Part III Sec. 4, No. 645
Effective from	1 October 2026 — retrospective, i.e. from the same date the principal regulations took effect
Amends	Principal Regulations FEMA 23(R)/2026-RB dated 13 January 2026 (as amended by FEMA 23(R)/(1)/2026-RB dated 22 September 2026)
Provisions touched	Reg. 2(1)(da) new definition; Reg. 3(2) new provisos (a), (b); Reg. 18(1)(d) substituted
Not touched	Goods exports/imports, realisation periods (9/12 months), software definition, Reg. 4(2) closure provisos

New definition: “resident individual” = a person resident in India who is a natural person. Proprietorships are therefore likely covered (the exporter is the individual); firms, LLPs, companies, trusts and HUFs are not.

Present vs revised requirements

The EDF form itself and the 30-day timeline remain for cases outside the new provisos. Revised position applies from 1 October 2026.

Area	Requirement as notified (1 Oct 2026, before this amendment)	Revised requirement (Second Amendment)
Service export — resident individual	Full EDF to AD bank (or STPI / SEZ DC) within 30 days from end of invoice month, regardless of value	EDF deemed submitted once the individual gives the AD bank the details needed to credit the inward remittance. No separate EDF, no value limit (Reg. 3(2) proviso (a))
Service export — other than resident individual (firm, LLP, company, trust, HUF)	Full EDF, same 30-day timeline, no threshold	Inward remittance ≤ ₹10 lakh: EDF deemed submitted on providing credit details to AD bank (proviso (b)). > ₹10 lakh: full EDF continues as before
Existing Reg. 3(2) provisos (monthly consolidated EDF; filing on/before receipt date; AD extension for late EDF)	Provisos (a), (b), (c)	Continue unchanged, renumbered (c), (d), (e)
Goods export / import	EDF via shipping bill; EDPMS/IDPMS against SB / BoE	No change

Threshold basis differs: export relief tests the value of the inward remittance; import relief tests the invoice or contract value.

Who is affected

Client profile	Impact	Net effect
Individual / proprietor exporting services (consultants, freelancers, designers, IT)	EDF requirement effectively removed	Major relief
Firm / LLP / company exporting services, remittances ≤ ₹10 lakh	Deemed EDF on remittance credit	Relief for small-ticket receipts
Firm / LLP / company exporting services, remittances > ₹10 lakh	Full EDF within 30 days from end of invoice month	No change — continue compliance
Individual paying foreign vendors for services (SaaS, consultancy, subscriptions)	No import-details entry; payment record still in IDPMS (open point 7)	Major relief
Entity importing services, invoice/contract ≤ ₹10 lakh	No import-details entry; payment record still in IDPMS (open point 7)	Relief
Entity importing services, invoice/contract > ₹10 lakh	IDPMS entry and closure continue	No change
Goods exporters/importers (incl. SEZ jewellery units)	Goods side untouched	No change; check any service receipts/payments separately

Open points to confirm with AD banks

The notification is short; these points will be settled by each bank’s revised policy/SOP under Reg. 19.

Proprietorships — a proprietor is a natural person, so proviso (a) should apply; confirm the bank treats proprietary-concern accounts this way.
Split remittances — export test is per inward remittance. An invoice above ₹10 lakh received in instalments each ≤ ₹10 lakh may technically qualify; banks may test at invoice level instead.
Timing of deemed EDF — deemed filing happens when credit details are given, i.e. on receipt. Where receipt falls after the 30-day EDF window, confirm the bank will not treat it as a late EDF.
EDFs already filed / entries already created (1 Oct – 2 Nov 2026) — amendment is retrospective. Confirm whether banks will auto-close or purge IDPMS entries ≤ ₹10 lakh and individual-importer entries created in this window.
Software exports — deemed EDF provisos refer to “exporter of services”; confirm banks apply them to software exports (designs, drawings, databases) as well.
Import contracts spanning many invoices — import test is “invoice or contract value”. A contract > ₹10 lakh billed in small invoices may still need IDPMS entry.
Outward payment record in IDPMS — Reg. 18(1)(e) (entry of outward remittances) and 18(1)(h) (marking off import entries on payment) are not amended. For imports where the AD no longer enters import details (resident individuals; others ≤ ₹10 lakh), confirm how the bank will close the payment record.