RBI FEMA Export-Import Second Amendment 2026: Deemed EDF for Service Exporters, Rs 10 Lakh IDPMS Test
RBI’s Second Amendment (2 November 2026) to the FEMA export-import regulations deems an exporter of services to have filed the Export Declaration Form on giving its Authorised Dealer (AD) the payment details: always for a resident individual, up to Rs 10 lakh for others. A Rs 10 lakh test also governs the AD’s import entries. Effective 1 October 2026.
Meera is a freelance translator living in India. Kite Digital Pvt Ltd is a small software firm. Both invoice overseas clients in November 2026, and both also buy services from abroad. Who has to file what?
| Case | Result under the amendment |
|---|---|
| Meera invoices Rs 4 lakh | A resident individual: deemed to have filed the EDF when she gives her AD the payment-receipt details so it can credit her account. No threshold in the clause |
| Kite receives Rs 6 lakh | Not an individual, remittance not more than Rs 10 lakh: deemed filed on the same basis |
| Kite receives Rs 12 lakh | Above Rs 10 lakh: the deemed route does not apply. The EDF is due within 30 days from the end of the month of the invoice, so an invoice of 12 November 2026 means 30 December 2026 (our counting) |
| Kite buys a Rs 15 lakh service from abroad | Its AD enters the import details in the import monitoring system within 5 working days of receipt of details |
| Meera buys a Rs 2 lakh service from abroad | She is a resident individual, so, our reading, the duty in the amended clause (d) does not cover her |
What do these terms mean?
EDF
The Export Declaration Form, in which an exporter declares the full export value. For services it is due within 30 days from the end of the month in which the invoice was raised.
Authorised Dealer (AD)
A person authorised as an authorised dealer under section 10(1) of FEMA. It receives the EDF details and makes the export and import entries.
EDPMS and IDPMS
RBI’s Export Data Processing and Monitoring System and Import Data Processing and Monitoring System, where ADs record and close export and import entries.
Resident individual
New definition: a person resident in India who is a natural person (regulation 2(1)(da)).
What is the parent framework?
The Foreign Exchange Management Act, 1999 (FEMA) is the law. Under it RBI issued the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (notification FEMA 23(R)/2026-RB, 13 January 2026; Official Gazette 15 January 2026). RBI’s circular of 16 January 2026 to Authorised Dealers says it reviewed the rules for exports and imports to promote ease of doing business, especially for small exporters and importers, and to let ADs serve customers faster. The regulations take effect on 1 October 2026, and the circular says the earlier Master Directions on export and import and the circulars it lists stand superseded from then. A first amendment (FEMA 23(R)/(1)/2026-RB, 22 September 2026) also came into force on 1 October 2026. The Second Amendment changes three places in the same text.
What changed?
BEFORE
Regulation 18(1)(d): the AD enters import-of-service details in IDPMS “as declared and submitted by the importer, within five working days of receipt of documents”.
NOW
The AD enters them “as furnished by the importer who is a person other than a resident individual and where the invoice or the contract value is more than ₹10 Lakh”, within five working days of receipt of details.
The amendment has three parts. Regulation 2 adds the definition of resident individual. Regulation 3(2) gains two new provisos, (a) for resident individuals and (b) for others up to Rs 10 lakh; the older provisos are renumbered (c) to (e), and they still allow a single EDF for several recipients in a month, an EDF on or before the receipt of payment for services other than software, and an AD-granted extension for delay. Regulation 18(1)(d) is substituted as shown above.
How do the pieces fit in time?
-
13 January 2026principal regulations
FEMA 23(R)/2026-RB issued; Gazette 15 January 2026. RBI’s AD circular follows on 16 January.
-
22 September 2026first amendment
Amends regulations 5 and 13 and adds regulation 20 (powers to Authorised Dealers). In force 1 October 2026.
-
1 October 2026go-live
The regulations and the AD circular take effect.
-
2 November 2026Second Amendment
Notified and gazetted, with effect from 1 October 2026.
Who is affected, and what should they check?
Exporters of services
Check each inward remittance against Rs 10 lakh. Above it, plan the EDF within 30 days of the end of the invoice month.
Authorised Dealers
Re-test EDPMS and IDPMS workflows: deemed EDF on receipt of payment details; IDPMS entry of import-of-service details as clause (d) now describes it.
Importers of services
Non-individual importers with invoices or contracts above Rs 10 lakh should expect the bank to enter details within 5 working days.
Finance teams
The amendment was notified on 2 November but dates from 1 October, so check October entries made before it with your AD.
When does it apply?
From 1 October 2026, as regulation 1(2) states. The notification is dated 2 November 2026.
Legal basis
- Power used
- Sections 7, 8, 10(6) and 47(2), Foreign Exchange Management Act, 1999
- Regulations amended
- Regulations 2(1), 3(2) and 18(1)(d), Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, notification FEMA 23(R)/2026-RB of 13 January 2026
- This notification
- FEMA 23(R)/(2)/2026-RB, 2 November 2026
Key facts
| Authority | Reserve Bank of India (RBI) |
|---|---|
| Instrument | Notification, Foreign Exchange Management (Export and Import of Goods and Services) (Second Amendment) Regulations, 2026 |
| Reference | Notification No. FEMA 23(R)/(2)/2026-RB |
| Issue date | 2 November 2026 |
| Effective date | 1 October 2026 |
| Change | Regulations 2(1)(da), 3(2)(a) and (b), 18(1)(d) |
| Threshold | Rs 10 lakh or equivalent in foreign currency |
| Last verified | 5 November 2026, against the four RBI pages listed under Sources |
Frequently asked questions
Does a resident individual still have to file an EDF for services?
The new proviso (a) treats the EDF as submitted when the resident individual gives the AD the information about receipt of payment, for crediting the account. The clause has no amount limit.
Is the Rs 10 lakh test the same for exports and imports?
No. For an exporter of services that is not a resident individual, the test is inward remittance “not more than” Rs 10 lakh. For the AD’s IDPMS entry, it is invoice or contract value “more than” Rs 10 lakh, for an importer that is not a resident individual.
Why does a notification dated 2 November 2026 apply from 1 October 2026?
Regulation 1(2) says the regulations come into force from 1 October 2026, the date the principal regulations take effect. RBI’s page for the principal regulations marks the new text as inserted with effect from that date.
Does it change anything for exports of goods?
The amendment touches the export-of-services declaration in regulation 3(2) and the import-of-services entry in regulation 18(1)(d). The goods declaration in regulation 3(1) is not amended.
Sources (official)
- RBI Notification FEMA 23(R)/(2)/2026-RB, Foreign Exchange Management (Export and Import of Goods and Services) (Second Amendment) Regulations, 2026, 2 November 2026 https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13750
- RBI page for the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, FEMA 23(R)/2026-RB, 13 January 2026 (text as amended) https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13277
- RBI A.P. (DIR Series) Circular No. 20, Export and Import of Goods and Services, 16 January 2026 https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13278
- RBI Notification FEMA 23(R)/(1)/2026-RB, Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, 22 September 2026 https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13714
- RBI
- Banking Regulations
- FEMA
- EDF
- IDPMS
- Exports of services
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