If you design logos, packaging or brand kits for overseas clients as an individual, RBI's position as stated on 7 October 2026 is that individuals providing services abroad are not required to report, which suggests you do not need to file the EDF. But the Regulations themselves have not been amended yet and RBI's promised FAQs are still awaited, so check with your bank. If you work through a proprietorship, partnership, LLP or company, assume the EDF applies to you.
Key takeaways
- On 7 October 2026, RBI's Governor said individuals providing services abroad are not required to report; the Deputy Governor said personal-contract transactions are outside the requirement.
- The text of the 2026 Regulations has not changed, and RBI said it would issue FAQs. Until then, ask your bank.
- Designers trading as a proprietorship, firm, LLP or company should assume they are covered and file monthly.
- Whatever your status, keep clean invoices and get a FIRA for every foreign payment.
- The EDF question has no bearing on your income tax or GST. Those apply as before.
What changed on 1 October and what RBI said a week later
The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 came into force on 1 October 2026. They require service exporters to declare exports on an EDF, generally within 30 days from the end of the month in which the invoice is raised, and to realise payment within 9 months.
The rules triggered alarm among freelancers. At RBI's policy press conference on 7 October 2026, the Governor said individuals providing services abroad, giving tutoring and small software work as examples, are not required to report. The Deputy Governor added that personal-contract transactions fall outside the reporting requirement. RBI said FAQs would follow.
That is a clear signal, but a press conference is not an amendment. Banks may wait for the FAQs before changing their processes. Read our summary of what RBI said about individuals on 7 October 2026 for more.
Are you an "individual" or a business?
This is the question that decides your position, and it is less obvious for designers than it sounds.
| Your set-up | Likely position today | What to do |
|---|---|---|
| Freelancer invoicing in your own name, paid into a savings account | Within RBI's 7 October statement on individuals | Ask your bank; wait for FAQs |
| Freelancer with GST registration, invoicing in your own name | Probably still an individual, but less clear | Ask your bank and CA |
| Sole proprietorship with a trade name ("Ira Studio"), current account | Treat as covered | File monthly EDF |
| Partnership or LLP design studio | Covered | File monthly EDF |
| Private limited design company | Covered | File monthly EDF |
Notice the middle rows. A proprietorship is legally the same person as its owner, but banks often treat a business current account in a trade name differently from a personal account. Until the FAQs settle it, proprietors should assume they need to file. If your bank tells you otherwise in writing, keep that letter.
A worked example: two designers, two answers
Ira works from Jaipur, designing packaging for a small tea brand in the UK. She invoices in her own name, receives GBP into her savings account through a payment platform, and earns around ₹9 lakh a year. Based on RBI's statement, she is the kind of individual RBI described. She asks her bank whether it expects an EDF; the bank says it is waiting for RBI's FAQs and will let customers know. She keeps her invoices and FIRAs organised in the meantime.
Kabir runs Northlight Design, a proprietorship in Bhopal with a current account, a GST registration and two junior designers. He invoices US and Australian clients in the business name. He treats himself as covered. If he raises three invoices in October 2026, he files one EDF with three rows by 30 November 2026. Because design is a service other than software, he also has the option of submitting on or before the date payment is received.
Same profession, different set-ups, different answers.
If you do file: what it looks like for a designer
- Type of export (1.1): Services.
- Mode of delivery (1.4): Internet, since files are delivered online.
- Part 2B: one row per invoice. Description like "Brand identity design: logo, colour palette and guidelines".
- SAC: design services are often coded 998393 (other specialty design), but confirm with your CA.
- Purpose code on receipts: design does not map to a single obvious RBI code. Ask your bank which code it expects and tell your clients.
Our free EDF form generator walks you through each field.
What every designer should do now, filing or not
Regardless of whether the EDF applies to you, these habits protect you:
- Invoice properly. Your name or business name, address, client's legal name and country, invoice number, date, currency, description and amount. If you are GST-registered and export under LUT, add "Supply meant for export under LUT without payment of IGST". Our export invoice tool produces a clean format.
- Get a FIRA or remittance advice for every foreign payment, from your bank or payment platform's settlement bank. Check the purpose code.
- Keep one folder per month with invoices and payment proof.
- Ask your bank, in writing, what it expects from individual freelancers. Keep the reply.
- Watch for RBI's FAQs and adjust when they arrive.
Tax reminders
The EDF is a FEMA declaration and does not change income tax or GST. Your foreign earnings are taxable in India. Many freelancers use the presumptive scheme in Section 44ADA where they qualify; your CA can tell you whether design work fits. GST registration and LUT depend on your turnover and circumstances, so check with your CA. This is general information, not legal or tax advice.
Frequently asked questions
Do I need to file the EDF as a freelance graphic designer working alone?
RBI said on 7 October 2026 that individuals providing services abroad are not required to report. The Regulations have not yet been amended, and FAQs are awaited, so confirm with your bank. Keep invoices and FIRAs in order meanwhile.
I have a proprietorship design studio. Am I covered?
Assume yes. Proprietorships, partnerships, LLPs and companies should treat the EDF as applicable until RBI's FAQs say otherwise. File one EDF a month listing all your export invoices.
What SAC code do graphic designers use on export invoices?
Design services are often coded 998393 (other specialty design), but classification depends on the work. Confirm with your CA and use the same code on every invoice.
I get paid through a payment platform. Who is my AD bank?
Usually the Indian bank where the platform settles the money into your account. If you are filing, that bank receives the EDF. Ask the platform and your bank how payment advices are issued.
Does skipping the EDF affect my income tax?
No. The EDF is a FEMA declaration. Your foreign earnings remain taxable in India, and GST rules apply as usual, whether or not you file an EDF.
Bottom line
Individual designers should check with their bank until RBI's FAQs arrive; studios and companies should file monthly. Either way, start with a clean export invoice and keep every FIRA.
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.