Data analytics companies that build dashboards, run models or manage data pipelines for clients abroad file a monthly EDF with their AD bank, or with STPI if the work is software. The first decision is one most analytics firms skip: is this month's work "Services" or "Software" in field 1.1? The answer affects where you may file and which deadline options you have, so settle it per line of business before you prepare your first form.
Key takeaways
- Field 1.1 asks for Goods, Services or Software. Analytics firms often have both services and software revenue.
- Software outside an SEZ can be filed with the AD bank or STPI. Services other than software go to the AD bank and can use the "on or before payment" alternative.
- Standard deadline for both: within 30 days from the end of the invoice month.
- Codes depend on the work: IT consulting (998313), IT design and development (998314), other IT services (998319), market research (998371). Confirm with your CA.
- Retainers, sprints and licence fees each produce clean Part 2B rows if invoiced separately.
Services or software: making the call
Analytics work spans a spectrum. At one end is pure consulting, where analysts interpret data and deliver insights. At the other is product engineering, where you build and hand over software, such as a data platform, a pipeline codebase or a machine learning model deployed in the client's environment.
| Kind of work | Leaning | Why |
|---|---|---|
| Analysis reports, insight decks, ad-hoc studies | Services | Output is advice and analysis, not code |
| Managed BI and reporting retainers | Services (often) | Ongoing service, though tooling is involved |
| Building data pipelines, ETL code, warehouses | Software | Deliverable is software or system design |
| Custom ML models delivered as code | Software | Deliverable is software |
| Licensing your own analytics platform | Software | Licence or subscription to software |
Where an engagement mixes both, many firms invoice the components separately. That keeps field 1.1 honest and lets you choose the right specified authority for each EDF. If you cannot split them, take your CA's view and ask your bank how it wants a mixed engagement presented. Our guide on software consultancy versus off-site software export purpose codes helps with the remittance side of the same question.
Why the choice changes your options
| Point | Software | Services other than software |
|---|---|---|
| Where to file (outside SEZ) | AD bank or STPI | AD bank |
| Standard deadline | 30 days from end of invoice month | 30 days from end of invoice month |
| Alternative: file on or before payment date | Not available | Available |
| Field 1.1 | Software | Services |
Because field 1.1 is a single choice per form, a firm with both kinds of revenue in one month usually prepares two EDFs: one for software invoices, one for services invoices. Ask your bank whether it wants them separately, which is the tidier approach.
Worked example: Quillon Analytics in January
Quillon Analytics Pvt Ltd, Bengaluru, has three revenue lines. Its January 2027 export invoices:
| Invoice | Client | Country | Amount | Work | Classification | SAC (confirm) |
|---|---|---|---|---|---|---|
| QA/27/004 | Harborview Retail Inc | USA | USD 15,000 | Managed BI reporting retainer, Jan 2027 | Services | 998313 |
| QA/27/009 | Elmstead Insurance plc | UK | GBP 22,400 | Claims data pipeline build, sprint 3 | Software | 998314 |
| QA/27/012 | Kaiser Logistik GmbH | Germany | EUR 3,900 | Demand forecasting study | Services | 998313 or 998371 |
| QA/27/015 | Elmstead Insurance plc | UK | GBP 1,800 | Platform licence, Jan 2027 | Software | Confirm with CA |
Quillon prepares:
- Services EDF: QA/27/004 and QA/27/012, filed with its AD bank.
- Software EDF: QA/27/009 and QA/27/015, filed with its AD bank (it could have chosen STPI).
Both are due by 2 March 2027. For the services invoices, Quillon could alternatively have filed on or before each payment date.
Billing patterns analytics firms use
Monthly retainers for managed analytics or embedded analysts: one invoice, one row, a description that names the month.
Sprint or milestone billing for builds: each sprint invoice is a row in the month it is raised. Use the statement of work number in the contract column so the bank can see sprints belong to one project.
Licence or subscription fees for your platform: monthly, quarterly or annual invoices, each a row in its month. Annual upfront licences arrive as large single amounts, so check whether they cross ₹10 lakh for realisation evidence purposes.
Usage-based charges, such as compute or data volumes passed through: describe them clearly, and if they are reimbursements of third-party cloud costs, take advice on whether they belong on the invoice as services. Our SaaS and usage billing guide goes deeper.
Realisation and payment evidence
Full value must be realised within 9 months from each invoice date. Large enterprise clients often pay on 45 to 90 day terms, which fits comfortably, but procurement disputes over sprint acceptance can stretch that. Keep sprint sign-offs on file; they help explain delays if you need an extension.
For invoices above ₹10 lakh, the bank closes the EDPMS entry on the invoice, payment evidence (FIRA or bank advice) and matching instructions. For invoices up to ₹10 lakh, a periodic declaration of realisation is enough for the bank to close the entry. Purpose codes on FIRAs should match the work: P0802 or P0807 for software, and an appropriate consultancy or research code for analysis work. Confirm with your bank.
GST and LUT
Analytics services and software supplied to clients abroad are generally exports of services under Section 2(6) of the IGST Act, and therefore zero-rated. Most firms export under LUT and print "Supply meant for export under LUT without payment of IGST" on each invoice. The EDF is a FEMA declaration and does not change GST or income-tax treatment. This is general information, not legal or tax advice.
Frequently asked questions
Should a data analytics company select Services or Software on the EDF?
It depends on the deliverable. Analysis, reporting and insight work usually lean towards Services, while building pipelines, platforms or deployable models lean towards Software. Many firms split invoices by type and file separate EDFs.
Can a data analytics firm file its EDF with STPI?
Only for software exports, and only if the firm is outside an SEZ. Software can be filed with the AD bank or STPI, since STPI certification is no longer mandatory. Services other than software go to the AD bank.
Which SAC code should a data analytics company use?
Common candidates include 998313 for IT consulting and support, 998314 for IT design and development, 998319 for other IT services and 998371 for market research. The right code depends on the invoice, so confirm with your CA.
How do I show platform licence fees on the EDF?
Each licence invoice is one row in Part 2B in the month it is raised, usually on a Software EDF. Use the licence agreement as the contract reference and describe the licence period.
What is the EDF deadline for analytics invoices raised in January 2027?
2 March 2027, because the deadline is 30 days from the end of January and February 2027 has 28 days. For services other than software, you may alternatively file on or before the date payment is received.
Bottom line
For analytics firms, classify each revenue line as services or software first, then let the rest of the EDF follow. Separate invoices make separate, clean forms. Prepare both with the free EDF form generator, and check exact deadlines with the EDF due date calculator.
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.