Goods exporters have filled export declarations for decades; most service exporters met the form only when the new rules started on 1 October 2026. Both use the same EDF from the Annex to the FEMA (Export and Import of Goods and Services) Regulations, 2026, but a services exporter fills Part 2B with one row per invoice, leaves the goods sections blank, and files monthly rather than shipment by shipment.
Key takeaways
- There is one EDF form. Goods go in Part 2A, services go in Part 2B, and you fill only your own part.
- Goods shipped through EDI ports use the shipping bill as the EDF. Services have no shipping bill, so you always submit the form itself.
- A single monthly EDF can cover every service invoice raised that month, to one or more clients, due within 30 days from the end of the month.
- Who receives your EDF depends on what you export and where you sit: AD bank, STPI or the SEZ Development Commissioner.
- Copying a goods template is the fastest way to make mistakes. Several goods fields simply read "N/A" for services.
Same form, different parts
The Annex is laid out in five parts. A goods exporter and a services exporter both touch Part 1, Part 4 and (indirectly) Part 5, but the middle of the form splits cleanly.
| Part of the EDF | Goods exporter | Services exporter |
|---|---|---|
| Part 1 – General information (1.1 to 1.22) | Fills everything, including shipping bill, port of loading, port of discharge and LEO date | Fills it, but 1.3, 1.14, 1.18 and 1.20 are N/A; mode of delivery is usually "Internet" |
| Part 2A – Goods | Fills it | Leaves blank |
| Part 2B – Services | Leaves blank | One row per invoice |
| Part 3 – Post/courier (FPO) | Fills it if shipping by post | Usually N/A |
| Part 4 – Declaration by exporter | Signs, striking out "services" | Signs, striking out "goods" |
| Part 5 – For the specified authority | Filled by the authority | Filled by the authority |
Part 2B is where the real work sits for services. Each row asks for the recipient's name and address, country, invoice number and date, currency, amount, net realisable value, description of services, SAC code, contract number and date, and remarks. If you raised seven invoices in a month, you have seven rows.
Why goods have a shipping bill and services don't
A container passes through customs. The shipping bill records what left, where it left from and when the Let Export Order was given, so at EDI ports that document can double as the export declaration. At non-EDI ports, goods exporters still use a manual EDF.
A website build or a month of bookkeeping crosses no port. Nothing is inspected, nothing gets an LEO date. That is why the EDF for services is a standalone document you prepare from your invoices, and why the shipping bill, port and LEO fields are marked not applicable. We cover this contrast in more detail in EDF vs shipping bill: why services don't have one.
Timing: per shipment vs per month
Goods declarations follow the cargo. Service declarations follow the calendar. Under Regulation 3(2), you file within 30 days from the end of the month in which the invoice was raised, and Regulation 3(2)(a) lets one EDF cover all of that month's service exports to one or more recipients.
A worked example
Kestrel Analytics Pvt Ltd in Pune raised three invoices in October 2026:
| Invoice | Client | Country | Currency amount | INR value in books |
|---|---|---|---|---|
| KA/26-27/041 | Harbour Retail Inc | USA | USD 12,000 | ₹10,02,000 |
| KA/26-27/042 | Fenwick & Doyle Ltd | UK | GBP 4,500 | ₹4,77,000 |
| KA/26-27/043 | Lumen Ventures Pte Ltd | Singapore | SGD 9,000 | ₹5,67,000 |
Kestrel files one EDF with three rows in Part 2B and a total of ₹20,46,000 in field 1.22, written in figures and words. The due date is 30 November 2026. A goods exporter shipping three consignments in the same month would be dealing with three separate shipping bills.
There is also an alternative for services other than software: you may submit the EDF on or before the date you receive payment. If Kestrel's work counted as non-software services and Harbour Retail paid in advance on 20 October, filing by then would also satisfy the rule. Check which route your AD bank prefers before relying on it.
Who receives the EDF
For goods, the process runs largely as before through customs documentation. For services, the specified authority depends on your situation.
| Your situation | Where the EDF goes |
|---|---|
| Services other than software, outside an SEZ | Your AD bank |
| Software services, outside an SEZ | Your AD bank or STPI (your choice) |
| Any unit inside an SEZ | The SEZ Development Commissioner |
| Goods through an EDI port | Shipping bill serves as the EDF |
| Goods through a non-EDI port | Manual EDF |
Your AD bank is normally the Authorised Dealer Category-I bank where the foreign money lands. The term "specified authority" is defined more fully in our glossary entry.
What happened to SOFTEX
Software exporters used to file a separate SOFTEX form, typically through STPI. That form is gone. Software is now declared on the same EDF, with 1.1 marked "Software", and AD banks are specified authorities on par with STPI. STPI certification is no longer mandatory.
Fields that trip up anyone copying a goods template
Reusing an old goods layout goes wrong in these fields:
- 1.4 Mode of transport/delivery. Goods use Air, Sea or Land. Work delivered online is "Internet".
- 1.12 Mode of realisation. Unless you have a letter of credit or bank guarantee, direct transfers and advances fall under "Others".
- 1.13 Consignee/recipient. For services this is the client receiving the service, not a freight consignee.
- Product code. Goods use HSN. Part 2B asks for a six-digit SAC code, such as 998314 for IT design and development. Our SAC code finder helps you pick one, but confirm it with your CA.
- Net realisable value. Each Part 2B row asks for NRV alongside the invoice amount. Fill it per row rather than leaving it to the bank.
What stays the same for both
The EDF remains a FEMA declaration. It does not change your GST or income-tax position, and the zero-rated treatment of export services under the IGST Act is unaffected. After filing, your bank enters the EDF into EDPMS within 5 working days, and the entry stays open until the money is matched.
Realisation then follows its own clock. For services, the full value must come in within 9 months from the invoice date, or 12 months where the invoice is in Indian rupees. For invoices up to ₹10 lakh, the bank may close the EDPMS entry on your declaration that the money has arrived; larger invoices need payment evidence such as a FIRA. This is general information, not legal or tax advice.
Frequently asked questions
Do service exporters fill Part 2A of the EDF?
No. Part 2A is for goods and stays blank on a services EDF. Service exporters enter each invoice as a separate row in Part 2B, with recipient details, invoice data, currency, amount, NRV, SAC code and contract reference.
Can one EDF cover both goods and services?
The form is shared, but field 1.1 asks you to choose one type of export: goods, services or software. A business exporting both should treat them as separate declarations and ask its AD bank how it wants them presented. Goods exported through EDI ports are already covered by the shipping bill.
Is the services EDF filed per invoice or per month?
Per month, if you prefer. Regulation 3(2)(a) allows one EDF to cover all service exports of a month to one or more recipients. It is due within 30 days from the end of that month, so October 2026 invoices are due by 30 November 2026.
Who is the specified authority for software exports?
Outside an SEZ, a software exporter may file with its AD bank or with STPI. AD banks now sit on par with STPI, and STPI certification is no longer mandatory. SEZ units file with the SEZ Development Commissioner instead.
Bottom line
The EDF for services and the EDF for goods share a form but almost nothing else in practice: different parts, different timing, different paperwork trail. Start from a services layout rather than a goods one. The free EDF form generator builds Part 2B rows from your invoices, and the EDF guide walks through every field.
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.