RBI's New FEMA Export Rules Are Live — What SaaS and Service Exporters Must Do

The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 came into effect on October 1, 2026, rewriting the compliance playbook for every Indian company that sells services abroad — from SaaS startups to IT services firms.

The key new requirement is the export declaration form (EDF): service exports must now be declared through the dealer's bank, and export proceeds must be realised within nine months — extended to 12 months for transactions settled in rupees. Exporters also face tighter invoice and foreign-receipt record-keeping.

After industry pushback over the paperwork burden, the RBI clarified on October 7, 2026 that individuals are not covered: freelancers, independent consultants, individual developers and creators exporting in their individual capacity have no EDF obligation. But companies, LLPs and firms must examine their position and align processes with their banks.

For early-stage SaaS founders, this lands squarely in the danger zone: missed realisation timelines and undocumented receipts now carry sharper FEMA exposure than before. The nine-month clock starts on the invoice, not on when the client decides to pay — so contracts, payment terms, and bank coordination all need a rethink.

The silver lining is that the RBI listened and carved individuals out. The expectation now is that dealer banks will operationalise EDF filing workflows quickly, and founders should pin their bank relationship manager down before the first declaration is due.