A 100% Export Oriented Unit that exports services files the same monthly EDF as any other service exporter, ticking "100% EOU" in field 1.5 (category of exporter). Because an EOU sits outside an SEZ, its EDF goes to its AD bank (or, for software, the AD bank or STPI), not to an SEZ Development Commissioner.
Key takeaways
- EOUs use the same EDF in the Annex to the 2026 Regulations; the category field is what sets them apart.
- Field 1.5 offers Custom DTA units, SEZ, 100% EOU, Warehouse export and Others; tick 100% EOU.
- EOUs are not SEZ units, so the EDF goes to the AD bank, or to the AD bank or STPI for software.
- Deadlines, the nine-month realisation rule and the ₹10 lakh declaration apply as usual.
- EOUs have other reporting duties under their own scheme; the EDF does not replace those.
Where EOUs fit in the 2026 Regulations
The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 apply by type of export and location, not by the scheme your unit operates under. The routing rule for services is:
| Location and export type | Where the EDF goes |
|---|---|
| Unit in an SEZ | SEZ Development Commissioner |
| Outside an SEZ, software | AD bank or STPI |
| Outside an SEZ, other services | AD bank |
An EOU is approved under a separate export-promotion scheme and is located outside an SEZ. So for EDF purposes it follows the outside-SEZ rows. If your unit has both an EOU and an SEZ presence, each unit follows its own route, and you should keep their declarations separate.
Filling field 1.5 correctly
Field 1.5 asks for the category of exporter. The choices on the form are:
- Custom DTA units
- SEZ
- 100% EOU
- Warehouse export
- Others
An EOU ticks 100% EOU. It sounds obvious, but this is the field that most often goes wrong when a finance team copies a template from a sister company in the domestic tariff area or a consultant's sample made for an ordinary firm. The bank uses this field to understand which rules and records apply, so an EOU marked "Others" or "Custom DTA units" invites questions.
Our article on category of exporter in the EDF compares every option.
A worked example
Saptagiri Data Services Pvt Ltd runs a 100% EOU in Chennai providing medical transcription and data annotation to clients in the US and UK. In November 2026 it raises five invoices:
| Invoice | Date | Client country | Currency | Amount |
|---|---|---|---|---|
| SDS/EOU/26-27/201 | 05-11-2026 | United States | USD | 14,200 |
| SDS/EOU/26-27/202 | 05-11-2026 | United States | USD | 9,850 |
| SDS/EOU/26-27/203 | 12-11-2026 | United Kingdom | GBP | 7,400 |
| SDS/EOU/26-27/204 | 20-11-2026 | United States | USD | 11,000 |
| SDS/EOU/26-27/205 | 28-11-2026 | United Kingdom | GBP | 3,950 |
Saptagiri prepares one EDF for November 2026 with five rows in Part 2B. In Part 1 it selects Services in 1.1, Internet as the mode of delivery in 1.4, 100% EOU in 1.5, its AD code in 1.6, its IEC in 1.7, GSTIN and PAN in 1.8 and 1.9, and Others as the mode of realisation in 1.12. It totals the rupee value in 1.22, in figures and words, signs Part 4 and submits to its AD bank by 30 December 2026.
When the US and UK payments land, the bank matches each against its row. Invoices up to ₹10 lakh can be closed on Saptagiri's periodic declaration of realisation; larger ones are closed with the invoice, FIRA and matching instructions.
Software EOUs: AD bank or STPI
Many EOUs are software units that historically worked closely with STPI. Under the 2026 Regulations, SOFTEX no longer exists, and AD banks are specified authorities on par with STPI. A software EOU can therefore submit its EDF to its AD bank or to STPI.
Which to choose is a practical question. If your payments land with one bank and your team already deals with its trade desk, filing there keeps declaration and matching under one roof. If your unit still has an active relationship with STPI for other approvals, you might prefer to keep using it. Either way, choose one route per month and stick with it so invoices do not get declared twice.
Records an EOU should keep
EOUs already live with heavier paperwork than most exporters. The EDF adds a monthly layer. A sensible EDF file for each month holds:
- The EDF as submitted, with the bank's or STPI's acknowledgement.
- Copies of every invoice listed in Part 2B.
- Contracts or statements of work referenced in the contract column.
- FIRAs, FIRCs or bank advices for each receipt.
- Any realisation declarations covering invoices up to ₹10 lakh.
- Correspondence on delays, extensions or corrections.
Keep an EDF register that links each invoice to its EDF month, payment date and closure status. The register is what you will reach for when your scheme's own performance reports ask for export realisation figures.
The EDF is a FEMA declaration. It does not replace the returns, performance reports or approvals that an EOU owes under its own scheme, and it does not change GST or income tax. Ask your CA or the authority that supervises your unit what those other filings need. This article is general information, not legal or tax advice.
Points EOUs tend to miss
Inter-unit or group billing. Some EOUs bill a foreign parent or group company on a cost-plus basis. Those invoices are still exports and still go on the EDF, with the relationship noted where relevant.
Domestic sales. If an EOU makes any permitted supply within India, those invoices are not exports and do not belong on the EDF.
Rupee invoicing. Where an invoice is raised and settled in Indian rupees, the realisation period is twelve months rather than nine.
Pre-October invoices. Invoices raised before 1 October 2026 are widely reported to fall outside the EDF. Confirm with your bank, especially if large old invoices are still unpaid.
Frequently asked questions
Does a 100% EOU file its EDF with the SEZ Development Commissioner?
No. The Development Commissioner route is for units located in an SEZ. An EOU sits outside an SEZ, so it files with its AD bank, or for software exports with its AD bank or STPI.
Which category should an EOU select in field 1.5?
Select 100% EOU. The other options, Custom DTA units, SEZ, Warehouse export and Others, apply to different kinds of exporters. Ticking the right category helps the bank apply the correct checks.
Is the EDF deadline different for EOUs?
No. The EDF is due within 30 days from the end of the month in which the invoices were raised. November 2026 invoices are due by 30 December 2026, for example.
Can an EOU still use STPI for software exports?
Yes. Software exporters outside an SEZ can file with either their AD bank or STPI. STPI certification is no longer mandatory, and SOFTEX has been replaced by the EDF.
Does the EDF replace an EOU's other compliance reports?
No. The EDF only covers FEMA export declaration and realisation. Any reports or approvals required under the EOU scheme, GST or income tax continue separately.
Bottom line
For an EOU, the EDF is the same monthly form everyone else uses, with one field that must say 100% EOU. Get that right, route it to the correct authority, and keep a tidy register. The free EDF form generator lets you set the category once and reuse it every month.
This guide is general information for Indian businesses, not legal or tax advice. Rules and bank processes change — confirm specifics with your AD bank or chartered accountant.