Service providers, chartered accountants and other experts said individual service exporters have been seeking support

Twenty-three days after the Reserve Bank of India’s Foreign Exchange Management Regulations went live, individual service exporters continue to face uncertainty over its compliance.

In the absence of official, written clarifications by RBI on the applicability of the new Export Declaration Form (EDF) regime for individuals receiving foreign remittance towards services rendered, different authorised dealer (AD) banks have taken different approaches and majority are also yet to put out their standard operating procedures (SOPs) as mandated by the regulator.

Service providers, chartered accountants and other experts told businessline that individual service exporters have been seeking support on whether they should be filing the EDF, which is quite complex requiring various information.

The regulations require all exporters to furnish it, but the RBI Governor, post the monetary policy in October, indicated that individuals undertaking transactions of a “personal nature” would not be covered, leading to the confusion.

Uncertainty and confusion

This uncertainty came into focus on Friday when Ramesh Srivats, a popular marketer, posted on X that his bank had asked him to fill an EDF for an inward forex remittance towards consulting services. Questioning whether an individual was even required to navigate a complex form spanning four spreadsheets, Srivats’ post drew responses from others who said they were facing similar requests. A few hours after his tweet went viral, Srivats said the bank contacted him to clarify that he need not file an EDF as an individual.

“We are hearing from banks that they expect RBI’s FAQs on this within the next one to two weeks. This could possibly clarify the exemption for individuals as well as reporting requirements for non-SWIFT settlement channels,” Rohan Sewani, Head of Operations & Customer Experience at Skydo, a cross border payments platform, said. Meanwhile, banks are adopting a cautious, compliance-first approach, he added.

Businessline spoke to two private banks; while one of them has not been insisting on EDFs from individuals, the other has been cautious and made it a standard practise to send the EDF to all service exporters whether they hold a business registration or not.

Additionally, RBI has also mandated banks to publish SOPs for the new reporting framework, but the rollout remains incomplete.

Businessline analysis of the Foreign Exchange Dealers’ Association of India (FEDAI) website as of Friday showed that only two out of the 90 banks listed therein have published their SOPs.

“We have seen a spike in customer support queries since October 1, largely from individuals seeking clarity on the process,” Sewani added.

At the moment, individual consultants, freelancers and other service providers receiving payments from overseas clients remain dependent on their bankers for guidance on compliance.

“The RBI Governor’s remarks are an indication of the regulator’s intent, but until the RBI issues the proposed FAQs or any other formal notification or guidance, AD banks may continue to seek compliance with the existing EDF reporting requirements for all,” Asish Philip Abraham, Executive Partner, Lakshmikumaran & Sridharan Attorneys, said. 

Published on October 23, 2026