Changes Relating to Exports
A. Export Declaration Form (EDF) for Services
The revised framework extends export declaration and reporting requirements to services.
Key changes include:
EDF requirements cover goods, software, and services.
Service export declarations are to be submitted to the bank within 30 days from the end of the relevant month.
A single monthly EDF may cover multiple service invoices.
PAN is mandatory for EDF submission.
Reporting requirements extend to exports such as free-of-cost (FOC) supplies, samples, and trade fair exports, as specified in the revised framework.
What businesses should do: Service exporters should review their invoicing, monthly reporting, PAN details, and supporting documentation to ensure that declarations are submitted within the applicable timelines.
B. Timeline for Realisation of Export Proceeds
The revised framework specifies different realisation timelines depending on the nature of the export transaction.
Type of export | Timeline indicated in the revised framework |
|---|---|
Exports invoiced in convertible foreign currency | 9 months from the date of export |
Warehouse exports | 9 months from the date of sale from the warehouse |
Exports invoiced in Indian rupees | 12 months from the date of export |
Bharat Mart warehouse exports | 9 months from the date of sale |
Project exports | As per the terms of the contract |
Exporters should monitor outstanding receivables carefully and maintain appropriate records of shipment dates, invoice dates, contractual payment terms, and amounts received.
C. Reduction and Write-Off of Unrealised Export Proceeds
The revised framework provides a mechanism for considering reductions and write-offs of eligible export bills.
Export bills up to ₹10 lakh may be considered for reduction or write-off based on the prescribed customer declaration.
Requests above ₹10 lakh may require additional documentation and enhanced review by the bank.
Requests remain subject to applicable conditions and the Authorised Dealer (AD) Bank’s verification.
Practical implication: Businesses should maintain evidence supporting the reasons for non-realisation, including customer correspondence, commercial disputes, settlement records, and other relevant documents.
D. Set-Off of Export and Import Transactions
The revised framework permits eligible set-off arrangements between export receivables and import payables, subject to prescribed conditions.
Important changes include:
Corresponding export and import transactions may fall in different calendar years.
Set-off may be permitted between goods and services, subject to applicable requirements.
Businesses using netting or set-off arrangements should obtain confirmation from their AD Bank regarding the permitted structure, documentation, and reporting requirements before completing the adjustment.
E. Extension of Export Realisation Period
Extensions may be considered where export proceeds cannot be realised within the prescribed period, subject to satisfactory justification and supporting documentary evidence.
Businesses should approach their AD Bank with a clear explanation of the delay and relevant supporting records.
F. Third-Party Export Receipts
Third-party receipts may be considered based on satisfactory documentary evidence, the commercial rationale, and due diligence.
The revised framework also permits consideration of receipts in a currency different from the invoice currency, subject to applicable requirements.
Exporters should ensure that the relationship between the buyer, payer, and exporter is properly documented and that the bank is satisfied with the transaction structure.
G. Advance Payments Against Exports
The revised framework links the export obligation timeline to the underlying contract for advance-payment transactions.
It also revises the framework for long-term export advances, including the earlier restrictions applicable to eligible long-term supply contracts.
Businesses receiving export advances should review contractual delivery obligations, refund provisions, interest conditions, and banking arrangements under the applicable regulations.
H. Unrealised Exports and Buyer-Specific Restrictions
The revised framework discontinues exporter-level caution listing, subject to transitional provisions for exporters already on the Caution List as of 30 September 2026.
Where export proceeds remain unrealised beyond one year from the due date or extended period, future exports to the concerned buyer must be supported by full advance payment or an irrevocable Letter of Credit, subject to the applicable provisions.
This is an important change for exporters dealing with overseas buyers who have delayed or defaulted on payments.
Businesses should regularly review buyer-wise outstanding export proceeds and assess the implications before accepting further orders from a buyer with overdue payments.