RBI’s formal EDF FAQ is still awaited, but banks have started publishing their EDF procedures.
I read AU Small Finance Bank’s 25 page EXIM Policy, effective 1 October 2026.
Here are 10 practical takeaways for service exporters :
1. Who is the “specified authority”?
For services other than software in the DTA, it is the AD bank. For software, it is the AD bank or STPI.
AU says the bank will upload the EDF to EDPMS within 5 working days of receipt.
2. How can you submit?
AU’s policy permits trade transaction requests through any branch or approved digital channel.
Forex-related cut-offs:
• Branch: 3:00 PM
• Digital: 3:30 PM
Complete, compliant requests are scheduled for same day handling.
3. What is the EDF deadline?
Within 30 days from the end of the month in which the invoice was raised.
One EDF can cover multiple overseas clients for the month.
Non software service exporters may alternatively submit the EDF on or before receiving payment.
4. Missed the deadline?
AU may grant an extension if you provide reasonable grounds. If approved, the revised due date will be communicated in writing.
Its policy also states that no penal charge or late-submission fee will be levied solely for regulatory delay.
5. The Rs 10 lakh provision:
For invoices up to ₹10 lakh, EDPMS entry closure may be based on the exporter’s declaration regarding realisation of payment.
A quarterly declaration for bulk closure is permitted, including for transactions through Payment Aggregator Cross Border (PA-CB).
Important: This is an entry-closure mechanism, not a blanket exemption from EDF filing.
6. No IEC?
AU’s policy allows certain inward remittances for service exports to be credited using the exporter’s PAN when IEC is unavailable, subject to supporting documents.
It states that IEC must subsequently be obtained and recorded within a reasonable period of 7–10 days after the funds are applied.
7. The export realisation deadline:
• Services: 9 months from the invoice date.
• Goods: 9 months from the shipment date.
• Exports invoiced or settled in INR: 12 months, counted from the applicable date for the export type.
AU may grant extensions of up to 6 months at a time, subject to its assessment.
8. What if export proceeds remain unrealised?
If proceeds remain unrealised beyond one year from the due date or any extended period, further exports may be restricted to full advance payment or an irrevocable Letter of Credit.
AU’s policy limits this restriction to the specific exporter overseas buyer relationship linked to the unrealised proceeds.
9. Holding export proceeds abroad?
Under AU’s policy, funds in an eligible exporter’s foreign currency account outside India must be used for imports or repatriated to India within the prescribed period:
• Other overseas jurisdictions: by the end of the following month.
• IFSC accounts: within 3 months.
10. What about individuals and freelancers?
RBI officials clarified on 7 October that transactions of a personal nature undertaken by individuals are outside the reporting requirements.
AU’s policy does not specifically resolve the boundary between personal transactions and commercial freelance or sole-proprietor exports.
Do not assume a blanket exemption until the applicable position is clear.