The monthly EDF for services under Circular No. 25: fields, formats and deadlines

What changed on 1 October 2026

The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 brought goods, services and software exports under one Export Declaration Form. The SOFTEX form that software exporters filed with STPI, and the general waiver that let most other service exporters skip the EDF altogether, both ended with the old regulations. A.P. (DIR Series) Circular No. 20 of 16 January 2026 announced the change; A.P. (DIR Series) Circular No. 25 of 28 September 2026 gives the operational guidelines and technical specifications that make it work from day one.

The practical effect: a services company that never filed anything with its bank beyond the invoice now has a monthly return to the AD bank, and the bank enters each declaration in EDPMS, where the invoice stays outstanding until the money arrives.

Who files, and with whom

The exporter of the service files. The specified authority is the AD bank through which the proceeds are, or will be, realised. Exporters of software may file with STPI as before, through its portal; a unit in a Special Economic Zone files with its SEZ authority. A company that realises through two banks files one EDF per bank, each covering the invoices that bank will see paid.

What the declaration carries

Circular No. 25 lists the data fields. The exporter's part names the company, its address, PAN (mandatory), IEC and GSTIN, the AD bank and its code, and the month declared. Each invoice line carries the buyer's name, address and country, the SAC code of the service (mandatory), a description, the invoice number and date, the currency and value, the net realisable value after any deduction agreed in the contract, the contract or agreement reference, the period of service and the mode of delivery (online, on-site, rendered in India to a visiting buyer, or mixed).

The circular also fixes the file formats a bank's system accepts: a structured file in the published XML / CSV schema for banks that take the EDF electronically, alongside the signed declaration itself. Keeping the invoice register in the circular's field order is the simplest way to produce either without re-keying.

When it is due, and what happens next

The consolidated EDF is due within 30 days from the end of the month in which the invoices were raised. An exporter of services other than software may instead submit it on or before the day the payment for those invoices comes in. The AD bank may extend the period on a written request with reasons. Once received, the bank enters the declaration in EDPMS within five working days and gives the exporter the EDF number, which then travels with every realisation against those invoices.

From there the ordinary export discipline applies: the proceeds must be realised within nine months of the invoice date, twelve when the invoice is raised or settled in rupees, and the entry closes in EDPMS when the bank reports the realisation, with the e-BRC following for exporters who claim benefits.

A month-end routine that works

• Check every services export invoice for the SAC code and the buyer's full address and country before the month closes; these are the fields banks send back.
• Group the month's invoices by the authority they go to, and produce one declaration per group.
• Submit by the 30th day after month end, or sooner if a payment is expected before that; ask for an extension in writing if you will miss it.
• Record the EDF number the bank gives you against every invoice it covers, so each receipt can be matched to its declaration.

FxLayer does this from the invoices already in the workspace: Service invoices › Monthly EDF groups every receipt invoice dated from 1 October 2026 by month and authority, flags the missing fields, produces the EDF as a PDF and a CSV in the circular's field order, emails it to the bank's trade-finance desk and records the number on each invoice. The due date sits on the Compliance calendar and the EDF register under Statutory reports.

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