India SME Forum (ISF) has requested the Reserve Bank of India (RBI) to suspend the recurring Export Declaration Form (EDF) filing requirement for 90 days for micro and small service exporters while a simplified mechanism is finalised. The requirement falls under the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026.
In a letter dated October 7 to the RBI, ISF said the final framework has no general turnover-based exemption. This, it said, could impose disproportionate compliance costs on freelancers, consultants, software and software-as-a-service (SaaS) providers, professionals and other small digital exporters, even when export proceeds are received through regulated banking or authorised payment channels.
During the monetary policy press meet last week, RBI Governor Sanjay Malhotra clarified that individuals undertaking transactions of a personal nature, including those providing small services to overseas clients, would not have to report them, irrespective of the amount. He also said exporters could use self-declarations instead of invoices for transactions of up to Rs 10 lakh per bill.
The forum said recurring EDF filing requires exporters to maintain invoice-level records, including customer and country details, currency and transaction value, contract information and service classification, besides reconciling receipts and following up with authorised dealer banks. This could be particularly burdensome for small businesses handling high volumes of low-value transactions without dedicated compliance teams. It acknowledged the facilitative provisions in the final rules, such as consolidated filing options, a payment-receipt filing route for non-software services and simplified closure for smaller invoices. But it said these do not remove the separate exporter-side declaration and reconciliation obligation.
ISF has sought a clear exemption or simplified annual compliance route for exporters below an appropriate annual export turnover or transaction-value threshold. It has also proposed bank-led, automated reporting, with exporters asked for information only when data is missing or discrepancies arise. For transactions that cannot be reconciled automatically, it wants consolidated periodic or annual self-declarations instead of repeated invoice-level filings.
The forum also called for uniform procedures across authorised dealer banks, including standardised documentation, transparent and capped charges, time-bound closure and an effective escalation mechanism. It has asked the RBI to ensure that legitimate export receipts are not delayed, rejected or subjected to adverse treatment solely because of initial EDF filing or reconciliation difficulties, subject to know-your-customer and anti-money laundering checks.
ISF said the concerns mirror those faced by goods and e-commerce exporters under the Export Data Processing and Monitoring System (EDPMS), where manual reconciliation, inconsistent bank interpretations, payment-platform deductions and purpose-code errors have caused delays despite evidence of legitimate receipts. It had flagged the compliance burden on micro, small and digital-first exporters in its comments on the draft FEMA regulations on July 31, 2025. It has now sought an urgent implementation review involving the RBI, the finance ministry, trade authorities, authorised dealer banks, payment providers and exporter representatives.
