RBI's New FEMA Export Rules Started on 1 October. Here's What Changes for Freelancers.

From 1 October 2026, every invoice you raise to a foreign client creates a record with the RBI, through your bank, that stays open until the money arrives.

That is the practical effect of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. The RBI notified them in January, amended them on 22 September, and they took effect this week. They replace the 2015 export regulations completely.

If you've already read about this, there's a good chance you read the wrong number. Most explainers, including bank and fintech blogs, were written before the September amendment and say you have 15 months to receive payment. The amendment cut that to 9.

Not legal or tax advice. This is a plain reading of the RBI's regulation text as amended up to 22 September 2026. Your bank's process and your CA's view of your facts come first.

The short answer

• You now declare your exports to your bank every month. One Export Declaration Form (EDF) covering all export invoices raised in a month, due within 30 days after that month ends. October's invoices: by 30 November 2026.
• Your client has 9 months from the invoice date to pay. 12 months if the invoice is in rupees or settled in rupees. Your bank can extend this if you ask with reasons.
• Small invoices get an easy path. Up to ₹10 lakh per invoice, the bank can close the entry, or even write off an unpaid amount, on your own declaration.
• SOFTEX is gone. Software exports use the same EDF as everything else.
• One bad client can follow you. If a payment stays unrealised for more than a year past its due date, further exports can only be made against full advance or a letter of credit.
• GST doesn't change. Your LUT, zero-rating and the Rule 96A one-year clock run exactly as before. The two systems still don't talk to each other.

What happened, and when

The September amendment is why so much of what's online is now wrong. Anything that tells you "15 months from 1 October" was accurate for eight months and stopped being accurate a week before the rules started.

What changes for you, in order of how much it matters

1. A monthly filing you didn't have before

Under the old rules, a freelancer exporting ordinary services (consulting, marketing, writing) filed nothing with the bank. Software exporters filed SOFTEX forms.

Now Regulation 3(2) says every exporter of services furnishes an EDF "specifying the amount representing the full export value of services, within 30 days from the end of month in which invoice for services has been raised." You can put all of a month's export invoices, across all clients, into a single EDF.

Your bank then has five working days to enter it into EDPMS, the RBI's export monitoring system. When the payment arrives, the bank matches it and closes the entry.

There is no minimum. A ₹15,000 invoice is an export like a ₹15 lakh one.

How to actually file it, month by month: The EDF Is Now a Monthly Filing. Here's Your Calendar.

2. Nine months, not fifteen

Regulation 5 requires the full export value of services to be "realised ... and repatriated" within nine months from the date of invoice. If the export is invoiced or settled in Indian rupees, it's twelve months.

Net-30 clients are nowhere near this. Long retainers billed upfront, milestone projects invoiced on signature, and clients who habitually pay late are where this bites. Your bank can extend the deadline if you ask before it passes and give reasons.

What happens at month 9, month 12 and month 21: Your Foreign Client Has 9 Months to Pay Now.

3. The ₹10 lakh declaration route

Two provisions make small exports far less painful:

• Closing entries. Where an invoice is up to ₹10 lakh, the bank can close the EDPMS entry "based on a declaration from the exporter" that payment has been realised, in full or otherwise. You can do this quarterly, in bulk.
• Writing off. Where an invoice is up to ₹10 lakh, the bank can allow a reduction in the export value, including total non-payment, on your declaration alone.

That second one is a real change. Under the old rules, writing off an unpaid export receivable needed justification and sometimes RBI involvement. It does not touch your GST liability, though, and that's the trap: You Can Now Write Off a Small Unpaid Export Invoice. GST Still Wants Its Money.

4. SOFTEX is gone, and "software" is wider than you think

The 2026 regulations define software as "any computer programme, database, drawing, design, audio/video signals, any information by whatever name called" on a non-physical medium. Designers and video editors are inside that definition. It matters because ordinary service exporters get an extra filing option that software exporters don't. Details: SOFTEX Is Gone. If You Send Designs or Code Abroad, You're a Software Exporter.

5. Advances go through the same bank as the balance

Regulation 10(1): if you receive an advance for an export, the advance and the final payment must route through the same bank. You can switch banks, but only after telling both of them.

If a client pays 50% upfront by wire to your HDFC account and the balance through a payment platform that settles into ICICI, that's now something to sort out before it happens, not after.

6. One unpaid client can restrict every other client

Regulation 13: if export proceeds stay unrealised for more than one year beyond the due date (or the extended date your bank allowed), you can make further exports only against full advance or an irrevocable letter of credit.

For a services invoice, that's 9 months to the due date plus 12 months: month 21. A freelancer whose every future client must pay fully upfront has a business problem, not a paperwork one. This is the strongest reason to ask your bank for an extension early, or use the ₹10 lakh write-off route, rather than let an old invoice sit.

7. Your bank has new obligations too

Regulation 19 requires every bank to publish a documented policy for export–import transactions: the documents it wants, its timelines, its charges, how extensions work, and an escalation and appeal mechanism for complaints. The main features of that policy must be on the bank's website.

It also says the bank "shall not levy any charges or penalty" on you for your own regulatory delay. That's not immunity from FEMA itself, but your bank can't fine you for a late EDF.

Practical step: search your bank's website for its FEMA export policy or SOP. That page is the closest thing to an answer key for how your bank will handle your EDF.

What doesn't change

• GST. The LUT, the zero-rated export invoice, and the Rule 96A clock are untouched. FEMA closing your entry does not cancel any GST liability, and vice versa.
• Purpose codes. Your bank still codes each inward remittance. A purpose code that doesn't match your work now has an EDF sitting next to it, which makes a mismatch more visible, not less.
• FIRA / FIRC. You still get remittance advice for each payment. It proves money arrived. It doesn't replace the EDF, which declares what's owed.
• Income tax. Nothing here touches how foreign receipts are taxed.

Invoices raised before 1 October

They stay under the old framework. No EDF is required for them, and the realisation period that applied when you raised the invoice still governs it. If one of those older transactions needed RBI approval for something (an extension, a write-off), Regulation 20 now lets your bank handle it directly.

What to do this month

1. 1.Ask your bank how it wants the EDF. Portal, email or paper. Ask which branch or team handles export of services. Find the bank's published FEMA export policy.
2. 2.If you're paid through a platform, ask it which bank holds your EDPMS entries and whether it files or helps file the EDF. Some have published guidance; others haven't.
3. 3.List every export invoice dated 1–31 October. Invoice number, date, client, country, currency, amount. That list is your first EDF; the free EDF form generator turns it into the form.
4. 4.Put 30 November in your calendar. Then the 30th of each following month, give or take.
5. 5.Check your payment terms. Anything where payment could land more than 9 months after the invoice date needs either different terms or an early extension request.
6. 6.Confirm your LUT for 2026-27 is filed. Nothing about FEMA changes that requirement. If it isn't: how to file an LUT.

Where Mavoin fits

The EDF asks for exactly what's on your export invoices: invoice number, date, client, country, currency and value. If those live in a clean register, the monthly filing is a ten-minute job. If they live in five PDFs and a bank statement, it isn't.

Mavoin keeps every export invoice in one place with its date, currency, rupee value and paid status, so you can see what's unrealised and how old it is, and export the list as CSV when your bank asks. GST-correct India invoices and multi-currency export invoices for ₹199/month, 30-day trial, no card.

Start your 30-day trial, or try the free export invoice generator.

Mavoin is not a Chartered Accountant service. Verify FEMA and GST specifics with your CA and your bank.