RBI drops separate export form for freelancers and small service exporters, from 1 October: what changes

The RBI has made three changes to the regulations.

First, it adds a definition. A "resident individual" now means a person resident in India who is a natural person. That brings freelancers and other individuals into the rules by name, separate from companies and firms.

Second, it adds two provisos to regulation 3(2). An exporter of services who is a resident individual is deemed to have submitted the Export Declaration Form once they have provided information on the payment received to their Authorised Dealer bank. There is no value limit for individuals. For all other exporters of services, such as firms and companies, the same deemed submission applies where the inward remittance is not more than Rs 10 lakh, or the equivalent in foreign currency.

Third, it narrows regulation 18(1)(d), which covers the Import Data Processing and Monitoring System, or IDPMS. Banks must now enter details of an import of services only where the importer is someone other than a resident individual and where the invoice or contract value is more than Rs 10 lakh or its equivalent. The earlier wording required the entry for service imports as declared by the importer, within five working days of receiving the documents. The new text refers to the receipt of details.

Why it matters

The Export Declaration Form was built for goods, where a shipping bill and a customs officer exist. Services such as code, design or consulting have no such moment at a port. For a person earning a few thousand dollars a month, a separate declaration meant extra work with a bank branch that often had no clear process for it. Treating the payment details as the declaration fits how the money actually arrives: the bank already knows who was paid, how much and from where.

The same logic runs through the larger rewrite. The RBI issued the new Export and Import of Goods and Services Regulations in January 2026, with Directions dated 16 January, effective 1 October 2026. Those Directions replaced two master directions and scores of older circulars, with the stated purpose of easing business for small exporters and importers. An October 2025 circular had already let banks close export and import entries of up to Rs 10 lakh on the basis of the exporter's or importer's declaration. The November amendment extends that threshold-based thinking to the point of filing.

For banks, the import change also cuts out a large number of small entries. A resident who pays a foreign subscription, or a small firm paying a foreign consultant a modest fee, will no longer generate an IDPMS entry.

What has not changed

The amendment reduces paperwork. It does not waive the underlying obligations. Exporters must still give their Authorised Dealer the payment details, so an individual should make sure the bank has the correct purpose code and invoice information for each receipt. Foreign exchange rules on where money may be received, and how it must be brought into India, continue under the regulations and Directions. Income tax and GST treatment is outside this notification altogether, so a freelancer's filing duties remain as they were.

Firms should read the Rs 10 lakh limit carefully. The export-side test is the inward remittance, while the import-side test is the invoice or contract value. An exporter above the limit continues to file as before.

One unusual feature is the date. The notification was issued on 2 November but applies from 1 October, so banks and customers have a month of transactions already completed under the new regime. The notification does not explain the backdating, but it does mean anyone who filed an unnecessary form in October lost nothing beyond the effort.

Individual service exporters should tell their bank that they fall under the resident individual provision and ask how the bank wants payment details recorded. Small firms should check whether each remittance is within Rs 10 lakh. Banks will need to update their internal processes, and the RBI's notification is the document to show a branch that has not yet caught up. The full text is on the RBI website under Notifications.