DevOps teams and managed services providers (MSPs) with foreign clients declare every monthly invoice on one EDF to their AD bank, filed within 30 days of month end. The structure of the form is simple; what makes MSPs different is the billing — fixed retainers, on-call fees, usage charges, re-billed cloud costs and SLA credits, sometimes all on one invoice. Get those right on the invoice and the EDF follows.
Key takeaways
- Each invoice is one Part 2B row; usage-heavy months don't need separate forms.
- Mode of delivery is Internet for remotely delivered operations and support.
- Common SAC codes: 998313 (IT support), 998315 (hosting and infrastructure), 998319 (other IT) — confirm with your CA.
- Cloud costs re-billed to clients raise GST and FEMA questions; separate them on the invoice and take advice.
- SLA credits reduce what you realise — reflect them through credit notes and in net realisable value.
The MSP invoice, line by line
A typical managed services invoice to a foreign client has several layers. Each has a likely SAC and a point to watch.
| Invoice line | Likely SAC (confirm) | What to watch |
|---|---|---|
| Monthly platform management fee | 998313 or 998319 | Describe the scope, not just "managed services" |
| 24×7 on-call / incident response | 998313 | Overage hours may vary month to month |
| Hosting or managed infrastructure you provide | 998315 | Distinguish from cloud you re-bill |
| CI/CD pipeline build or migration project | 998314 | Often a separate project invoice |
| Re-billed cloud costs (client's usage) | Ask your CA | Pass-through vs your own supply |
| SLA credit | — | Usually via credit note, reducing realisable value |
Whatever the mix, the EDF sees one invoice, one row. The invoice amount, currency, NRV, description and SAC go into Part 2B. Where an invoice has several SACs, ask your bank how it wants them shown; some exporters list the main code and keep the breakdown on the invoice.
Re-billed cloud costs
Many MSPs pay the cloud bill on the client's behalf and recover it, sometimes with a margin. This is the part of MSP billing most likely to trip you up:
- GST. Whether the recovery is part of your export of services or a separate pure-agent reimbursement depends on your contract and how you invoice. That's a question for your CA.
- FEMA. If you pay a foreign cloud provider and recover the cost from a foreign client, you have outward and inward flows linked to one arrangement. Banks may ask about it. Talk to your AD bank before structuring it that way.
- EDF. If the recovery is on your export invoice, the invoice goes on the EDF in full. Our article on reimbursement of expenses from foreign clients looks at how reimbursements are handled.
The cleanest practice is to show cloud recovery as a separate line with its own description, so everyone can see what it is.
Worked example: Stackmint Cloud Ops LLP
Stackmint, a 20-person MSP in Kochi, runs infrastructure for three clients. Its December 2026 invoices:
| Invoice | Client (country) | Lines | Currency | Amount | Approx. INR |
|---|---|---|---|---|---|
| SCO/26/212 | Pelican Logistics (Netherlands) | Platform mgmt EUR 6,000 + on-call overage EUR 900 | EUR | 6,900 | ₹6,21,000 |
| SCO/26/213 | Quarry Health (USA) | Managed hosting USD 3,200 + re-billed cloud USD 4,100 | USD | 7,300 | ₹6,06,000 |
| SCO/26/214 | Tidewater Games (Singapore) | Kubernetes migration, milestone 1 | SGD | 9,500 | ₹5,98,000 |
One EDF, three rows, total about ₹18,25,000, due 30 January 2027. Mode of delivery: Internet. Mode of realisation: Others.
In January, Pelican's platform suffers a four-hour outage, and Stackmint's contract gives a 5% SLA credit on December's management fee — EUR 300. Stackmint issues a credit note against SCO/26/212 and Pelican pays EUR 6,600. Stackmint tells the bank which invoice the payment relates to and attaches the credit note, so the EDPMS entry can be closed for the reduced amount. Our credit note generator produces a GST-format note that references the original invoice.
Codes: SAC and purpose
Operations and support work most often sits in 998313 (IT consulting and support) or 998319 (other IT services). Infrastructure you provide is 998315. Build projects — pipelines, migrations, automation — are closer to 998314. Your CA should confirm which fits each line; the SAC code finder is a quick reference.
Purpose codes are assigned by the bank on the inward payment. For software-related services, P0802 (software consultancy/implementation) and P0807 (off-site software exports) are common. Check every FIRA and confirm the code with your bank.
Software or not: does it change your deadline?
The EDF due date is the same for everyone: 30 days from the end of the invoice month. But the alternative of filing on or before the payment date applies to services other than software. Whether managed operations count as "software" exports under the Regulations isn't something we can settle for you — some MSP work is clearly software, some is infrastructure and support. If you rely on the alternative date, confirm with your bank. Otherwise, simply file on the month-end schedule.
Software exporters outside an SEZ can file with the AD bank or STPI; STPI certification is no longer mandatory. Most MSPs find it simplest to file with the bank that receives the money.
GST and LUT
Export of services is zero-rated under Section 16 of the IGST Act when the Section 2(6) conditions are met. Most MSPs export under an LUT on Form GST RFD-11 and print "Supply meant for export under LUT without payment of IGST" on each invoice. One condition deserves attention for MSPs with group structures: supplier and recipient must not be merely establishments of a distinct person. If your client is your own foreign parent or branch, take advice.
This is general information, not legal or tax advice.
Realisation and long contracts
MSP contracts run for years, and monthly invoices pile up. Each invoice has its own 9-month realisation window. Keep a register that shows, for every open invoice, the date it falls due for realisation. Smaller invoices (up to ₹10 lakh) can be closed through a periodic realisation declaration once paid — a quarterly rhythm suits MSPs well.
Frequently asked questions
Do managed services providers file one EDF per client?
No. One EDF per month can cover all service exports to one or more recipients. Each invoice is a separate row in Part 2B, whichever client it belongs to.
How should an MSP show re-billed cloud costs on the EDF?
If the cloud recovery is on your export invoice, the full invoice goes on the EDF. Whether that recovery is part of your export service or a pure reimbursement is a GST and contract question — show it as a separate invoice line and ask your CA.
What SAC code fits DevOps services?
It depends on the work: 998313 for IT support and consulting, 998315 for hosting and infrastructure, 998314 for building pipelines or systems, and 998319 for other IT services. Confirm with your CA.
How do SLA credits affect the EDF?
An SLA credit reduces what the client pays. Issue a credit note against the original invoice and tell your bank which payment relates to it, so the EDPMS entry can be closed for the reduced amount.
Is mode of delivery Internet for remote infrastructure management?
Yes, for operations and support delivered remotely. If engineers travel to the client's site, discuss with your bank whether a different option better describes that work.
Bottom line
For MSPs, the EDF is easy once the invoice is clean: separate lines for management, hosting, projects and re-billed cloud, with credit notes for SLA credits. Prepare the month's form in the free EDF form generator and keep matching notes handy.
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.