Weeks after the Reserve Bank of India’s (RBI) new foreign exchange reporting regulations for export and import of goods and services took effect, individuals exporting services, as well as micro, small and medium enterprises (MSMEs), are struggling to get their payments credited, as banks are asking them to fill out a complex, five-page export declaration form (EDF) as a prerequisite.According to the RBI, beginning October 1, an exporter of services must furnish a declaration in the EDF, specifying the full export value of the services within 30 days from the end of the month in which the invoice was raised. The catch, however, is that individuals — such as freelancers and consultants — are exempt from this requirement.The fact that banks are still asking individuals to fill the form points to a patchy implementation of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations — which, to be sure, were issued as far back as January 13, around eight months before the October 1 deadline.No FAQ by RBIOn October 7, Deputy Governor Rohit Jain had said that the intent of the new trade regulations was to “simplify the processes” and “promote ease of doing business”.“So, there seems to be some misunderstanding on the reporting obligations, which we will clarify shortly through an FAQ,” Jain had added.However, no FAQs have been issued so far by the central bank. And banks are clearly unwilling to move ahead by removing the burden from individuals despite both Jain and Governor Sanjay Malhotra saying publicly that individuals “irrespective of the amount, are not required” to report the information. This includes things like personal consumption payments, like paying overseas for foreign newspapers or TV channels or providing services abroad as an individual, such as tuition.Also Read | Is inflation becoming more widespread? RBI’s rate-setters are divided, and that’s a worry“As already clarified by Rohit (Jain), it’s important. That’s why I am repeating this for the benefit of your viewers,” Malhotra had added on October 7. The benefits, however, are not being felt by individuals.Story continues below this adAccording to information available on the website of the Foreign Exchange Dealers’ Association of India, only two banks — HDFC Bank and State Bank of India — out of 90 provide a policy framework for customers to understand the trade regulations that came into effect from October 1.Strangely enough, HDFC Bank, too, has been highlighted on social media as requiring individual service exporters to fill the Export Declaration Form — although it dialled back the demand and called the demand an “oversight” after one particular case went viral. But more on that later.MSMEs voice concernMSMEs, meanwhile, have approached the RBI seeking urgent intervention regarding the Export Declaration Form reporting and reconciliation requirements.India SME Forum president Vinod Kumar, in an October 7 letter to the RBI, said that the final EDF framework does not provide a general turnover-based exemption for micro and small service exporters.Story continues below this adAs a result, freelancers, consultants, software and SaaS providers, professionals, digital businesses and other small service exporters can be brought into a recurring FEMA declaration process even where export proceeds are received transparently through regulated banking or authorised payment channels, Kumar said.Graphs, Data, Perspectives | As Europe sees protest wave, understanding the economics of social unrest“This is not merely an additional form. For a micro enterprise or an individual exporter with a lean team and no dedicated FEMA or compliance function, recurring EDF preparation requires invoice-level records, customer and country details, currency and value data, contract information, service classification, reconciliation of receipts, and subsequent follow-up with the Authorised Dealer bank. The compliance cost can therefore become material in relation to the value of the export itself, particularly for high-frequency, low-value digital service transactions,” Kumar said.Kumar said that a one-size-fits-all framework, without differentiated treatment for MSMEs and digital-first exporters, would impose disproportionate compliance costs and create uncertainty for freelancers, SaaS providers, D2C and other emerging export models. “We had also proposed simplified, technology-enabled and proportionate compliance, including de minimis treatment and aggregate/self-declaration mechanisms for smaller exporters,” he said.Banking related challengesA social media post by content creator Ramesh Srivats on the troubles he faced in receiving payments from abroad — despite the RBI’s clarifications on individuals — has been widely shared.Story continues below this adSrivats said that EDF filing is riddled with complexities and runs into five sheets.“At least for me, most of the details are constant. One client, one payment. If it’s a one-time exercise, fine. I’ll grit my teeth and get it done. But no. These details have to be given month after month. Else… no payment will be credited. It would have been simple enough for RBI or HDFC to create an online portal for this. With dropdowns, saved formats, contextual help, etc. to at least make this easy. But that would be too convenient, no? So, they’ve chosen to dump the entire burden on the taxpayer,” he said.Ajay Srivastava, the head of think tank Global Trade Research Initiative, posted on social media that the RBI should come out with more clarity. “For instance if I receive $100 from the US do I need to file an EDF when it is a gift from my brother, payment for tutoring students or a fee for management consultancy,” Srivastava said.India SME Forum also asked RBI to prescribe a common digital procedure, definitive document checklist, transparent and capped charges, time-bound closure standards and an effective escalation mechanism. “Avoid repeated requests for information already available within the banking or regulatory system and prohibit avoidable professional certification demands for routine small-value transactions,” the forum said.