RBI Notification No. FEMA 23(R)/(2)/2026-RB, dated 2 November 2026, amends the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. It creates deemed EDF submission routes for service exports and limits the service-import details that authorised dealer banks must enter in IDPMS.
What changed for service exporters?
The principal regulations ordinarily require a service exporter to furnish an Export Declaration Form (EDF) within 30 days from the end of the month in which the invoice is raised. The amendment adds two situations in which the EDF is treated as submitted when the exporter gives the bank the information needed to credit the service receipt.
| Exporter | When EDF is deemed submitted | ₹10 lakh condition |
|---|---|---|
| Resident individual | When the individual gives the authorised dealer the information required for crediting the service-export payment. | No monetary ceiling is stated in this new proviso. |
| Person other than a resident individual | When the person gives the authorised dealer the information required for crediting the service-export payment. | The inward remittance for the service must not exceed ₹10 lakh, or its foreign-currency equivalent. |
“Resident individual” is newly defined as a natural person resident in India. A proprietorship should therefore confirm with its authorised dealer how the bank will map the account holder and transaction under this definition rather than assuming that every small-business receipt automatically qualifies.
What changed for service importers?
For imports of services, the authorised dealer must enter details in the Import Data Processing and Monitoring System (IDPMS) within five working days of receiving the details only where both conditions are met:
- The importer is not a resident individual. The amended clause applies to an importer who is a person other than a resident individual.
- The value exceeds ₹10 lakh. The invoice or contract value must be more than ₹10 lakh, or the equivalent in foreign currency.
The five-working-day clock is an obligation on the authorised dealer after receipt of the details. Businesses should nevertheless send accurate invoice, contract and payment information promptly so the bank can complete any required IDPMS entry.
Who is affected?
| Transaction | Practical effect |
|---|---|
| Freelancer or other resident individual exporting services | EDF is deemed submitted when the required receipt information is given to the authorised dealer for crediting the account. |
| Company, LLP, firm or other non-individual exporting services | The same deemed-submission route applies only where the inward remittance for that service does not exceed ₹10 lakh. |
| Resident individual importing services | The amended Regulation 18(1)(d) does not require the authorised dealer to enter that service import in IDPMS. |
| Company, LLP, firm or other non-individual importing services | The bank's five-working-day IDPMS entry requirement applies when the invoice or contract value is above ₹10 lakh. |
What should businesses do now?
- Classify the customer correctly. Record whether the exporter or importer is a resident individual or another type of person.
- Test the right amount. For exports by non-individuals, the notification refers to the value of the inward remittance for the service. For imports, it refers to invoice or contract value.
- Give the bank complete data. Keep the invoice, contract, purpose code, counterparty details and remittance advice ready, and follow the authorised dealer's operating process.
- Do not treat reporting relief as payment relief. The amendment changes EDF and IDPMS mechanics; it does not remove the underlying rules on genuine transactions, realisation of export proceeds or payment for imports.
- Review transactions from 1 October. Because the amendment is effective from that date, reconcile service receipts and payments processed since then with your bank.
Reviewed on 5 November 2026. This note is limited to the Second Amendment Regulations and should be read with the consolidated FEMA regulations and the authorised dealer's documentation process.