Is There an EDF or SOFTEX Waiver for Low-Value Exports?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
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- Last modified:
Short answer
There is no EDF waiver for low-value exports from 1 October 2026. Every exporter of goods, software or services must file the EDF, whatever the value. The relief for small exports is different: for shipping bills or invoices up to ₹10 lakh, the AD bank can close EDPMS entries on the exporter's own declaration.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| Exporters of goods, software and services of any value, including freelancers and small exporters with invoices of ₹10 lakh or less | Regulations 3, 4(2), 6 and 19 of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (FEMA 23(R)/2026-RB), in force from 1 October 2026 | EDF for goods at the time of export; EDF for services and software within 30 days from the end of the invoice month. Declarations for EDPMS closure up to ₹10 lakh can be given per invoice or quarterly in bulk | No penalty specific to low-value exports is set out in the 2026 regulations. An AD bank cannot charge a penalty for the exporter's regulatory delay (Regulation 19(3)) | 8 Oct 2026 |
What was the EDF and SOFTEX waiver for low-value exports?
The EDF and SOFTEX waiver for low-value exports was an older rule that let exporters skip the export declaration form when the value was small. RBI raised that limit to USD 25,000 in 2004. The 2026 regulations that took effect on 1 October 2026 contain no value-based waiver at all.
- Before 2004: Regulation 4(d) of the 2000 export regulations waived the GR, SDF, PP or SOFTEX declaration if the exporter declared that the goods or software were worth not more than Rs 25,000 (A.P. (DIR Series) Circular No. 61, para 1).
- From April 2004: RBI revised the limit to USD 25,000 or its equivalent and waived the GR, SDF, PP and SOFTEX forms for goods and software up to that value, from 1 April 2004 (Circular No. 61, paras 2 and 4).
- Still realise: Even under that waiver, exporters had to realise and repatriate the export proceeds in line with FEMA (Circular No. 61, para 2).
- 2015 rules: Regulation 4 of the 2015 export regulations listed exemptions such as trade samples supplied free of payment, travellers' personal effects and gifts of goods declared to be worth not more than five lakh rupees, with no USD 25,000 entry (FEMA 23(R)/2015-RB, Regulation 4).
- SOFTEX: Under the old Master Direction, software exporters filing bulk SOFTEX had to list all invoices, including those below US$25000 (Master Direction, para B.5(i)).
- Now: From 1 October 2026, Regulation 3 requires every exporter of goods and every exporter of services to furnish an EDF, with no value threshold (FEMA 23(R)/2026-RB, Regulation 3).
The old waiver circulars, the Master Direction and the SOFTEX circulars all stand superseded from 1 October 2026 (A.P. (DIR Series) Circular No. 20, para 4 and Annex). For how to fill in the current form, see EDF form for exports.
Who still has to file an EDF for a low-value export from October 2026?
Every exporter of goods and every exporter of services, including software, has to file an EDF from 1 October 2026, even for a small invoice. The only carve-out in Regulation 3 is for travellers moving personal effects, who are not treated as exporters.
| Exporter or export | EDF needed from 1 Oct 2026? | Why | Best for |
|---|---|---|---|
| Goods exporter, any value | Yes, at the time of export | Regulation 3(1) has no value limit; at an EDI port the shipping bill counts as the EDF | Small goods and ecommerce exporters |
| Service exporter other than software, any value | Yes, within 30 days from the end of the invoice month, or on or before the payment date | Regulation 3(2) and 3(2)(b) | Freelancers and consultants with small invoices |
| Software exporter, any value | Yes, within 30 days from the end of the invoice month | Software counts as a service under the Explanation to Regulation 2(1) | Developers who once relied on the SOFTEX waiver |
| Traveller carrying personal effects | No | Not treated as an exporter under the second proviso to Regulation 3(1) | People relocating abroad with belongings |
| Gift of goods or free trade sample | No exemption is listed in the 2026 regulations | The 2015 exemption list in Regulation 4 has no counterpart in the 2026 text; check with your AD bank or Customs | Exporters sending samples or gifts |
How do small exporters use the low-value relief under the 2026 FEMA export regulations?
Small exporters use the low-value relief by filing the EDF as normal and then giving the AD bank a declaration to close each EDPMS entry of ₹10 lakh or less. The relief simplifies closure and value reduction. It does not remove the EDF itself.
- File the EDF with your specified authority. For services, one EDF can cover all exports made to one or more recipients in a month (Regulation 3(2)(a)).
- Receive the payment through your AD bank. The bank credits your account after checking that the transaction is genuine and closes or updates the EDPMS entry at the same time (Regulation 4(2)).
- For a shipping bill or invoice up to ₹10 lakh or its equivalent in foreign currency, give the AD bank a declaration that the payment has been realised, in full or otherwise (first proviso to Regulation 4(2)).
- If you prefer, give that declaration once a quarter so the AD bank can close several entries in bulk (first proviso to Regulation 4(2)).
- If the client paid less than the invoice, or did not pay, and the export value is up to ₹10 lakh per shipping bill or invoice, ask the AD bank to allow the reduction on your declaration (proviso to Regulation 6).
- Keep realising every invoice within the period in Regulation 5: nine months from the shipment or invoice date, or twelve months if invoiced or settled in rupees.
How did the ₹10 lakh EDPMS declaration rule start before the 2026 regulations?
RBI first allowed AD banks to close EDPMS entries of ₹10 lakh or less per entry or bill on the exporter's declaration through A.P. (DIR Series) Circular No. 12 of 1 October 2025. The 2026 regulations now carry the same idea in Regulations 4(2) and 6.
- The 2025 circular also allowed quarterly consolidated declarations for bulk closure and acceptance of value reductions on declaration (Circular No. 12, para 3).
- It told AD banks to review charges on small-value transactions and not to levy penal charges for delays (Circular No. 12, para 4).
- Circular No. 12 is itself listed as superseded from 1 October 2026 in the Annex to Circular No. 20.
How did the EDF waiver for free-of-cost goods exports work before October 2026?
Before October 2026, AD banks could grant an EDF waiver to status holder exporters sending freely exportable items free of cost for export promotion, within an annual limit (A.P. (DIR Series) Circular No. 53, 2016). This was a waiver for free supplies, not for low-value sales.
- From the 2016 circular, the annual limit was Rs 10 lakh or 2% of average annual export realisation over the preceding three licensing years, whichever was lower (Circular No. 53, para 2).
- The Master Direction later set different annual limits, with separate rules for gems and jewellery and for pharmaceutical supplies to international health programmes (Master Direction, para C.1).
- Both are superseded from 1 October 2026 (Circular No. 20, para 4).
How did service exporters without a SOFTEX form avoid a declaration before October 2026?
Before October 2026, a service exporter whose service was not covered by any prescribed form could export without furnishing any declaration, while still having to realise and repatriate the proceeds (Master Direction, para B.7). From 1 October 2026, that clarification no longer applies.
- From 1 October 2026, Regulation 3(2) requires every exporter of services to file an EDF (FEMA 23(R)/2026-RB).
- See do freelancers need to follow FEMA export rules and does a freelancer need to file SOFTEX.
What documents are still needed for low-value exports from October 2026?
Low-value exports still need the EDF, the invoice or shipping bill it covers, and the payment through an AD bank. For entries of ₹10 lakh or less, the AD bank may close the EDPMS entry based on the exporter's declaration. Your AD bank's SOP lists the exact documents.
| Document or step | When needed | Low-value relief | Source | Best for |
|---|---|---|---|---|
| EDF for goods | At the time of export; deemed filed with the shipping bill at an EDI port | None; required at any value | Regulation 3(1) | Goods exporters |
| EDF for services and software | Within 30 days from the end of the invoice month | One EDF can cover a whole month's exports | Regulation 3(2)(a) | Freelancers and IT exporters |
| Declaration of realisation | When asking the AD bank to close an EDPMS entry | Accepted for shipping bills or invoices up to ₹10 lakh, per entry or quarterly in bulk | First proviso to Regulation 4(2) | Exporters with many small invoices |
| Request for reduction or non-realisation | When the client pays less or nothing | Declaration is enough up to ₹10 lakh per shipping bill or invoice | Proviso to Regulation 6 | Exporters facing short payment; see invoice value reduced after shipment |
| Request for extra time | When the EDF or payment is late | None specific; the AD bank decides on reasons given | Regulations 3(2)(c) and 5(1) | Exporters who missed a deadline |
| AD bank's own document list | For every export process | Each AD bank sets it in its internal policy and SOP | Regulation 19(1)(a) and 19(4) | Anyone unsure what their bank wants |
What happens if a small exporter skips the EDF because the export value is low?
A small exporter who skips the EDF on the assumption that low-value exports are waived is not following Regulation 3, since no such waiver exists from 1 October 2026. The 2026 regulations do not set a separate penalty for this. The AD bank will follow up with the exporter for the documents needed to close the EDPMS entry.
- Late EDF: For services, the AD bank may extend the time to file the EDF if you give reasons and it finds them reasonable (Regulation 3(2)(c)).
- Open entries: The AD bank must monitor EDPMS entries and follow up with the exporter for documents needed to close them (Regulation 18(1)(f)).
- Unrealised exports: If proceeds stay unrealised for over one year past the due or extended date, further exports need full advance or an irrevocable letter of credit (Regulation 13).
- Bank charges: An AD bank must keep charges reasonable and must not charge a penalty for the exporter's regulatory delay or violation (Regulation 19(3)).
If you skipped EDFs for small service invoices raised on or after 1 October 2026, write to your AD bank, give the reasons, ask for an extension under Regulation 3(2)(c), and file a single EDF per month for the missed invoices. Then use the ₹10 lakh declaration route to close the entries. See EDPMS closure.
Which RBI rules set and then removed the EDF and SOFTEX waivers for low-value exports?
Circular No. 61 of 2004 set the USD 25,000 waiver, and later rules narrowed exemptions to specific cases such as gifts and free supplies. Circular No. 20 of 2026 supersedes those circulars, and Regulations 3, 4(2) and 6 of the 2026 regulations now set the rules, with a ₹10 lakh declaration route in place of a waiver.
| Circular or regulation | Clause | Date | Plain meaning | Best for |
|---|---|---|---|---|
| A.P. (DIR Series) Circular No. 61, RBI/2004/35 | Paras 1, 2 and 4 | January 31, 2004 (date as listed in Circular No. 20); effective 1 April 2004 | Raised the declaration waiver from Rs 25,000 to USD 25,000 for goods and software | Understanding where the USD 25,000 figure came from |
| A.P. (DIR Series) Circular No. 73, RBI/2004/66 | Paras 1 and 2 | 20 February 2004 | Raised the gift exemption from one lakh to five lakh rupees per annum | Exporters who sent gifts abroad |
| FEMA 23(R)/2015-RB | Regulation 4 | 12 January 2016; superseded 1 October 2026 | List of exports that needed no declaration, including gifts up to five lakh rupees | Exports made before 1 October 2026 |
| A.P. (DIR Series) Circular No. 53, RBI/2015-16/332 | Para 2 | 3 March 2016 | EDF waiver for status holders exporting goods free of cost, within an annual limit | Status holders sending free promotional goods |
| A.P. (DIR Series) Circular No. 12, RBI/2025-26/89 | Paras 3 and 4 | 1 October 2025 | EDPMS entries of ₹10 lakh or less closed on the exporter's declaration | Small exporters clearing old entries |
| A.P. (DIR Series) Circular No. 20, RBI/2025-26/194 | Para 4 and Annex | 16 January 2026; effective 1 October 2026 | Supersedes the Master Direction and the circulars above, including SOFTEX circulars | Checking whether an old waiver still applies |
| FEMA 23(R)/2026-RB | Regulations 3, 4(2), 6 and 19 | 13 January 2026, amended 22 September 2026; in force 1 October 2026 | EDF for all exports; ₹10 lakh declaration route for closure and reduction | Every exporter from 1 October 2026 |
What are the common mistakes about EDF waivers for low-value exports?
- Old threshold: Relying on the USD 25,000 waiver from 2004, which is not part of the 2026 regulations.
- Waiver confusion: Reading the ₹10 lakh rule as an EDF waiver. It only lets the AD bank close EDPMS entries or accept reductions on your declaration.
- Services habit: Assuming freelancers still need no declaration, as under para B.7 of the old Master Direction, for invoices raised from 1 October 2026.
- Per-invoice filing: Filing a separate EDF for each small service invoice when one EDF can cover all of a month's service exports.
- Missed realisation: Treating a small invoice as exempt from the realisation period. Regulation 5 applies at every value; see export realisation period.
- Wrong period: Applying 2026 rules to exports made before 1 October 2026, which the superseded rules still cover for things already done.
How did we verify this?
Every rule, deadline and form on this page is linked to its official source, checked on the dates below.
- Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification FEMA 23(R)/2026-RB dated 13 January 2026, amended up to 22 September 2026, Preamble, Regulations 1(2), 2(1), Explanation to 2(1), 3, 4(2) and first proviso, 5(1), 6 and proviso, 13, 18(1)(f), 19(1)(a), 19(3), 19(4) (checked 8 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 20, RBI/2025-26/194: Export and Import of Goods and Services, 16 January 2026, Paras 1, 4 and 7; Annex A, items 31, 33, 83, 86 and 96 (checked 8 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 61, RBI/2004/35: Exemption from Declaration of Export of Goods and Software, Paras 1, 2, 4 and 5 (checked 8 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 73, RBI/2004/66: Export of Goods by way of Gifts - Liberalisation, 20 February 2004, Paras 1 and 2 (checked 8 Oct 2026)
- Foreign Exchange Management (Export of Goods and Services) Regulations, 2015, Notification FEMA 23(R)/2015-RB dated 12 January 2016, as amended, Regulation 4 (Exemptions) (checked 8 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 53, RBI/2015-16/332: Grant of EDF Waiver for Export of Goods Free of Cost, 3 March 2016, Paras 1 and 2 (checked 8 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 12, RBI/2025-26/89: EDPMS and IDPMS reconciliation of export/import entries, Review of Guidelines, 1 October 2025, Paras 2, 3 and 4 (checked 8 Oct 2026)
- RBI Master Direction: Export of Goods and Services (FED Master Direction No. 16/2015-16), updated as on 17 July 2026, superseded from 1 October 2026, Paras B.5(i), B.7, B.12, C.1 and C.31 (checked 8 Oct 2026)
Frequently asked questions
Does the USD 25,000 EDF waiver still apply to small exports?
No. The USD 25,000 waiver came from RBI's A.P. (DIR Series) Circular No. 61 of 2004, which Circular No. 20 of 2026 lists as superseded. From 1 October 2026, Regulation 3 of the 2026 regulations requires an EDF for every export of goods or services, with no value threshold.
Is the ₹10 lakh limit in FEMA 23(R)/2026-RB an EDF waiver?
No. The ₹10 lakh limit in Regulations 4(2) and 6 lets the AD bank close an EDPMS entry, or accept a reduced or nil realisation, based on your own declaration. You still file the EDF under Regulation 3. The limit applies per shipping bill for goods or per invoice for services.
Can the ₹10 lakh EDPMS declaration be given every quarter instead of per invoice?
Yes. The first proviso to Regulation 4(2) lets an exporter give the realisation declaration to the AD bank on a quarterly basis for bulk closure of EDPMS entries. Each shipping bill or invoice covered must be up to ₹10 lakh or its foreign currency equivalent. Ask your AD bank for its declaration format.
Do software exporters still file SOFTEX for small invoices after October 2026?
No. The SOFTEX circulars stand superseded from 1 October 2026 under Circular No. 20. Software counts as a service under the 2026 regulations, so software exports are declared in the EDF within 30 days from the end of the invoice month. A single EDF can cover a whole month's invoices.
Are gifts of goods up to five lakh rupees still exempt from the EDF?
The five lakh rupee gift exemption was in Regulation 4(d) of the 2015 regulations, which the 2026 regulations replaced on 1 October 2026. The 2026 text has no list of exemptions apart from travellers' personal effects. Check with Customs or your AD bank before sending a gift shipment abroad.
Which rules apply to small exports made before 1 October 2026?
The 2026 regulations supersede the 2015 regulations except for things done or omitted before the supersession. So an export made before 1 October 2026 was governed by the old rules, including any waiver that then applied. Under Regulation 20, AD banks now handle older cases that needed RBI approval.
Can an AD bank charge extra fees on small export invoices under the 2026 regulations?
Regulation 19(3) says AD bank charges must be reasonable and proportional to the service given. It also bars the AD bank from levying any charge or penalty for the exporter's regulatory delay or violation. Each AD bank must publish its policy and SOP features on its website under Regulation 19(4).