What the bank email is asking for
The Reserve Bank told authorised dealers, in Circular 20 of 16 January 2026, to follow the new export regulations and to tell their customers. That is the email. The regulations themselves, FEMA 23(R)/2026-RB, start on 1 October 2026.
If you raise an invoice for services, you are an exporter of services for this filing. The regulations do not have a separate freelancer form, and they do not set a turnover below which the declaration disappears. Software exporters who have been on SOFTEX move to the same form. That cutover is on the SOFTEX page. This page is the services case, including work that is not software.
Send the bank's email and one invoice, and we will say whether an export declaration is due this month.
When you file, and with whom
For services other than software, the specified authority in the domestic tariff area is your authorised dealer, the bank. You give it an Export Declaration Form for the full export value.
The timing in regulation 3(2) is within 30 days from the end of the month in which the invoice was raised. One form can cover every recipient you invoiced that month. For services other than software, you may instead file on or before the date the payment arrives. The bank may extend the filing period if you ask and it is satisfied with the reason.
The money has to be realised and brought to India within nine months from the invoice date. If the invoice or the settlement is in rupees, that period is twelve months. The bank may extend realisation if it accepts the reason you give.
The declaration and the bank advice are different papers
The regulations say the bank credits or debits your account only after it is satisfied the transaction is genuine, and it then closes or updates the entry in the export monitoring system. A shipping bill or a service invoice of up to ₹10 lakh can be closed on your declaration, including a quarterly declaration for a batch. That closure rule is not a rule that you skip the Export Declaration Form.
The form does not use the words FIRC or FIRA. Those are the names banks use for an advice that foreign exchange arrived. The GST side of an export, including the letter of undertaking, is a different statute. It is on the LUT and bank-advice page.
No separate DGFT notification was found that changes this for a freelancer. Project exports take their meaning from the Foreign Trade Policy. The filing authority for ordinary services is the bank.