A CA firm that keeps books, prepares tax returns or advises clients abroad is itself a service exporter, and from 1 October 2026 that means a monthly EDF to its AD bank listing every foreign invoice. Partnership firms and LLPs should assume they are covered; the 7 October 2026 RBI remarks about individuals do not reach a practice organised as a firm, and even sole practitioners should confirm with their bank before relying on them.
Key takeaways
- Your firm's own export invoices go on its own EDF, separate from any EDF work you do for clients.
- Outsourced accounting for foreign CPA firms, tax preparation and cross-border advisory are all service exports.
- Likely codes: SAC 998222 for accounting and bookkeeping; purpose code P1005 for accounting, auditing and tax consulting. Confirm both against your actual engagements.
- Tax season can multiply your invoice count. Think about invoicing structure before February, not in April.
- Most CA firm invoices fall under ₹10 lakh, which makes the periodic realisation declaration route especially useful.
Wearing two hats
Many CA firms are about to manage EDFs for clients, which is a service in itself. Our article on managing monthly EDFs for multiple clients covers that workflow. This article is about the other hat: your firm as the exporter.
The overlap is a trap. A firm that prepares twenty client EDFs each month can easily forget its own, especially when its foreign work is a side line. Put your firm's EDF on the same compliance calendar you use for clients, with its own owner.
What CA firms typically export
| Engagement | Typical foreign client | Billing pattern |
|---|---|---|
| Outsourced bookkeeping and accounts | CPA and accounting firms in the US, UK, Australia, Canada | Monthly retainer per client or per staff member |
| Tax return preparation | Overseas accounting firms, sometimes individuals abroad | Per return, heavy in their tax season |
| Financial statement preparation and review support | Foreign firms and companies | Fixed fee per engagement |
| Advisory on India entry, transfer pricing, FEMA | Foreign companies investing in India | Hourly or fixed fee |
| Payroll and compliance processing | Foreign businesses with Indian operations | Monthly |
All of these are exports if the recipient is outside India, the place of supply is outside India and payment arrives in convertible foreign exchange, among the other Section 2(6) conditions. The last category, advisory for a foreign company about its Indian operations, deserves a careful place-of-supply review, because work closely tied to Indian assets or events can raise questions. You will know the GST rules better than most readers; the point is to apply them to your own invoices with the same rigour.
Codes for CA firm exports
| Service | SAC to consider | Purpose code to consider |
|---|---|---|
| Bookkeeping, accounts preparation | 998222 (accounting and bookkeeping) | P1005 (accounting, auditing, tax consulting) |
| Tax preparation and tax advisory | The relevant tax-services code in the same group (confirm the exact six digits) | P1005 |
| India-entry and business advisory | 998311 (management consulting) | P1006 (business and management consultancy) |
Use one code per service line and keep it stable. When a foreign client's bank sends a remittance with a generic purpose code, ask your AD bank to correct it; a mismatch between your SAC and the purpose code is a small issue that becomes tedious at year-end reconciliation.
Tax season and invoice volume
Overseas tax seasons bring a burst of per-return invoices. A firm that invoices every return separately might raise 150 invoices in March, which means 150 rows in that month's Part 2B.
Nothing in the Regulations stops you from listing 150 rows, but you might reconsider the invoicing structure itself. Some firms agree with their CPA clients to invoice once a month per client, with a schedule of returns attached. That is a commercial and GST decision, not an EDF one, so weigh time-of-supply and contract terms before changing it. Either way, the EDF mirrors whatever invoices you actually raise.
A worked example
Mehta Rao & Associates LLP, a 30-person CA firm in Ahmedabad, has a 12-person team that does bookkeeping and tax preparation for three CPA firms in the US and one in Canada. Its foreign receipts land in its current account with a public-sector AD bank.
For March 2027 it raised monthly invoices per client, each with a schedule:
| Invoice | Client | Country | Description | Amount |
|---|---|---|---|---|
| MRA/EX/0331-1 | Larkin & Doyle CPAs | USA | Bookkeeping, 14 entities; 62 individual returns | USD 11,900 |
| MRA/EX/0331-2 | Pinecone Tax Group | USA | 48 individual returns | USD 7,200 |
| MRA/EX/0331-3 | Hollis Accounting PLLC | USA | Bookkeeping, 9 entities | USD 4,050 |
| MRA/EX/0331-4 | Northshore CPA Ltd | Canada | Year-end file preparation | CAD 6,300 |
The March 2027 EDF is due 30 April 2027, with four Part 2B rows. The first invoice, at an illustrative ₹84 per dollar, comes to about ₹10 lakh, so the firm checks it against the limit carefully: at ₹9,99,600 it would fall within the declaration route, but at a slightly higher conversion it would not. Rather than relying on a borderline figure, the firm plans to give the bank full evidence (invoice, FIRA, matching instructions) for that one, and covers the other three in its quarterly realisation declaration.
Because March is also the financial year end, the firm checks the same week that its LUT for FY 2027-28 is in place before raising April invoices.
Realisation and follow-up
CPA clients generally pay against monthly statements, but delays happen, especially after their busy season. The full value must be realised within 9 months from each invoice date. If a client is slow, the AD bank can extend the period on a reasoned request; ask before the deadline, not after.
Keep the FIRA for every remittance, check the purpose code, and map each payment to invoices in your EDF register. Your audit team would expect that of a client; expect it of your own firm.
GST and LUT
Your exports are zero-rated supplies when the Section 2(6) conditions are met. Under LUT (Form GST RFD-11), no IGST is charged and the invoice carries "Supply meant for export under LUT without payment of IGST". The EDF does not change GST or income-tax obligations. Our export invoice generator includes the LUT wording by default. This article is general information, not legal or tax advice, even for readers who give such advice for a living.
Frequently asked questions
Does a CA firm with foreign clients need to file the EDF?
A CA firm organised as a partnership or LLP should assume it is covered and file a monthly EDF for its export invoices. RBI's 7 October 2026 remarks concerned individuals, and FAQs are still awaited. Sole practitioners should check with their bank.
Which purpose code applies to outsourced accounting for US CPA firms?
P1005 (accounting, auditing, bookkeeping and tax consulting) is the natural starting point. Confirm with your AD bank, and ask it to correct any remittance tagged with an unrelated code.
Can we list a hundred tax-season invoices on one EDF?
Yes. One EDF per month covers all service exports of that month, with each invoice as its own Part 2B row. You may also want to review whether monthly consolidated invoicing suits your clients better, subject to GST rules.
Is advisory for a foreign company's Indian subsidiary an export?
It may be, but it needs a careful look at place of supply and who the recipient is. If the service relates closely to Indian operations or the recipient is effectively in India, export status can be questioned. Review each such engagement before treating it as zero-rated.
Should our firm's EDF go to the same bank as our clients' EDFs?
No link exists between them. Your firm's EDF goes to the AD bank where your own foreign receipts land. Each client files with its own AD bank.
Bottom line
A CA firm's own exports deserve the same discipline it brings to client compliance: one owner, one calendar, one register. For the related question for individual practitioners, see whether chartered accountants with foreign clients need to file, and prepare your firm's monthly form with the free EDF form generator.
This guide is general information for Indian businesses, not legal or tax advice. Rules and bank processes change — confirm specifics with your AD bank or chartered accountant.