Key takeaways
- Service exporters now file an EDF with their bank: one per month, within 30 days of month-end.
- October 2026 invoices: EDF due by 30 November 2026.
- Make your own invoice; match the name to the SWIFT remitter, with an annexure for platform payments.
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What changed
- RBI’s Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 replaced the old export rules. Service exports, not just software, now need an export declaration with the bank.
- One EDF can cover all of a month’s service invoices, filed within 30 days of the end of the month in which the invoices are raised. For October 2026 invoices, that is by 30 November 2026.
- You file with your bank (the AD bank); the bank reports to RBI. Export proceeds should normally be received within nine months of the invoice.
“Google or Upwork doesn’t give me an invoice”
You make the invoice yourself. It does not need to come from the payer.
- Your details: name, address, PAN, and GSTIN if registered.
- Billed to: the entity you contract with. For AdSense in India this is Google Asia Pacific Pte. Ltd., Singapore; for marketplaces, check your platform terms.
- Service, period and amount in the foreign currency, matching the payment.
- Invoice number and date, and your LUT reference if you are under GST.
When the remitter name doesn’t match
Banks often insist that the name on the invoice matches the remitter in the SWIFT message. Platform payments come from a payment entity (for example an escrow or payments company), not from your client. A practical fix is one monthly invoice addressed to the remitter exactly as it appears in the SWIFT message, describing the services delivered through the platform, with an annexure listing each underlying client invoice and the platform’s transaction statement. Confirm with your bank before you rely on it.
GST and income tax still apply
- If you are GST-registered, file an LUT so your exports are zero-rated, and report them in GSTR-1. See GST on export of services and LUT.
- Export income is taxable in India like any other income; keep the bank’s inward remittance advice (e-FIRA) with your invoices.
Monthly checklist
- Raise invoices for all foreign clients or platforms for the month.
- Match each payment to an invoice and the SWIFT remitter.
- File one EDF for the month with your bank within 30 days of month-end.
- Keep the e-FIRA, invoices and EDF acknowledgement together.
Sources
- EY: RBI issues Export and Import of Goods and Services Regulations, 2026
- LKS: RBI releases FEMA 2026 export-import regulations
- Skydo: EDF filing guide 2026 for service exporters
- Google AdSense Help: contracting entity and tax invoices
Frequently asked questions
Do freelancers need to file an EDF in 2026?
Banks are asking service exporters, including freelancers, for an Export Declaration Form under the FEMA export regulations that apply to services from October 2026. One EDF can cover all of a month's service invoices and is filed with your bank within 30 days of the month-end.
What is the EDF deadline for October 2026 invoices?
30 November 2026, because the EDF for a month's service invoices is due within 30 days from the end of the month in which the invoices were raised.
How do I create an invoice for AdSense income?
Make it yourself: your name, address and PAN, billed to Google Asia Pacific Pte. Ltd., Singapore (the AdSense contracting entity for India), describing the publisher services for the month, with the amount in US dollars matching the payment, an invoice number and date, and your LUT reference if GST-registered.
My bank says the invoice name must match the SWIFT remitter. What do I do?
Address a monthly invoice to the remitter exactly as named in the SWIFT message, describe the services delivered through the platform, and attach an annexure listing the underlying client invoices and the platform statement. Check with your bank that it will accept this.
Please note: this guide is general information based on the rules as they stood on the review date above. Regulations and RBI/CBDT procedures change often — please get advice on your specific facts before acting.