Eagle Eye
The circular, then what it actually says.
The standing translations live here. The dated diary — warnings as they land, contributed by the CAs, with tags and a calendar — is Eagle Eye. Official text is linked. Not legal advice — your CA still signs.
Eagle Eyea CA · FEMA 23(R)/2026-RB
From 1 October 2026, service exports are formally declared.
Until now a lot of freelancers treated a Wise credit and a FIRC as “done.” The new regulations say every export of services needs an Export Declaration Form. Software, design, writing, teaching on Zoom — if the client is abroad, it is an export. The switch flips on 1 October, not “sometime later.”
Notification FEMA 23(R)/2026-RB · 13 Jan 2026 ↗
Eagle Eyea CA · A.P. (DIR) Circular 20
One EDF a month. Due 30 days after month-end.
You do not file a form per invoice. You bundle every foreign invoice from that calendar month into one EDF. Invoice in October? File by 30 November. Your AD bank then has five working days to put it into EDPMS. Miss the window often enough and credits get slower, not because RBI froze you overnight, but because the bank cannot match money to a declaration that isn’t there.
A.P. (DIR Series) Circular No. 20 · 16 Jan 2026 ↗ · EDF form (PDF) ↗
Eagle Eyea CA · Circular 12 / 2025-26
Small invoices can close on your word.
If a single EDPMS entry is ₹10 lakh or less, your bank may close it on a declaration that the money has arrived — you do not need a novel of paperwork. Several such entries can go in one quarterly declaration. That is the relief. It is not a free pass to skip the EDF itself.
A.P. (DIR Series) Circular No. 12 · 1 Oct 2025 ↗
Eagle Eyea CA · realisation clock
Bring the money home in 15 months.
The EDF says you exported. The realisation rule says the rupees (or the EEFC dollars) must actually arrive, generally within fifteen months of the invoice — eighteen if you billed in INR. Sit on an unpaid invoice past that and future exports can be restricted to full advance or a letter of credit. Collect. Match. Close.
Same Circular No. 20, realisation provisions ↗