The scorecard the RBI finally published

From 1 October 2026, RBI's Export & Import of Goods and Services Regulations are in force — one Export Declaration Form for goods, services and software, 167 circulars superseded. If you export a logo design to a client in Berlin, you are now an "exporter" in the same legal sentence as a textile mill.

The interesting part for this register is not the rule. It is what RBI attached to it: a Statement on feedback received — a first for this desk, where the usual practice is silence, and SEBI/IBBI at best dump raw comment PDFs nobody can search.

What the ledger of asks shows

Sixteen items went in during two draft rounds (July 2024, April 2025). Our case file scores every one. The pattern is blunt:

• The banked interests won timing and discretion. AD banks — the only commenter class RBI names in so many words — got their five working days for E/IDPMS entry. Trading houses got merchanting-trade routing relaxed. Project exporters lost the PEM rulebook and got, in exchange, "ADs can handle transactions as per their internal policy" — which is where the rule that bites you now lives: unpublished, bank-by-bank, no consultation.
• The unorganised class lost the substantive ask. The single most consequential item — exempt service exports from the EDF, or keep the old waiver — was rejected on one line: Section 7 of FEMA makes declaration mandatory. What survived was procedural: one consolidated monthly form, any invoice value, threshold-based closure of small entries.

So the freelancer invoicing $5 for a gig now carries the same declaration duty as a $5m contract, with s.13 FEMA headroom of three times the sum involved, and proceeds held until the EDPMS match. The design choice — no de minimis floor, unlike the US's $2,500 Electronic Export Information exemption — is RBI's, not the statute's.

Transparency: better, still anonymous

Credit where due: RBI summarised the feedback and mapped each ask to the regulation that answered it. But the annex summarises without names, without counts. "ADs had requested" is the only attribution in the document. Who asked that service exports be exempt? Who asked the PEM be retained? The annex won't say. That is an RTI question now, and it is going on ours.

The case file carries the full scorecard, the timeline, the raw annex (archived, since rbidocs serves a captcha wall to scripts), and the watchpoints we will track — starting with commenter identities.