A digital marketing agency with foreign clients files one EDF a month listing every export invoice raised that month: retainers, project fees, performance bonuses and any separately invoiced ad-spend recharges. Mode of delivery is almost always Internet, and the realisation clock for each invoice runs nine months from its date. The awkward parts for agencies are mixed invoices, media pass-throughs and clients who pay a month late every month.
Key takeaways
- Every export invoice, including retainers and recharges, becomes one row in Part 2B of your monthly EDF.
- Mode of delivery is usually Internet; mode of realisation is usually Others.
- SAC codes often used: 998361 (advertising) and 998371 (market research); purpose code P1007 covers advertising, trade fair and market research. Confirm both.
- Separate invoices for agency fees and ad-spend recharges make matching and GST far easier.
- Recurring late payers need watching: each invoice has its own nine-month window.
How agency billing maps onto the EDF
The EDF follows invoices, not clients or contracts. Under the 2026 Regulations, one form per month can cover all service exports to one or more recipients, with each invoice as a separate row. Agencies tend to raise several types of invoice, and all of them count.
| Invoice type | Example | On the EDF? |
|---|---|---|
| Monthly retainer | "SEO and content retainer, November 2026" | Yes, one row each month |
| Project fee | "Website relaunch campaign, phase 1" | Yes |
| Performance bonus | "Lead-volume bonus, Q3" | Yes, when invoiced |
| Ad-spend recharge | "Paid social media spend recharged at cost" | Yes, if invoiced to the foreign client; ask your CA about GST treatment |
| Tool or licence recharge | "Analytics tool seat, recharged" | Yes, if invoiced |
If you are not sure whether a recharge is part of your export, our article on reimbursement of expenses from foreign clients covers the grey areas.
Choosing SAC and purpose codes
The EDF asks for a SAC code on each row. Digital marketing work does not sit neatly in one code, so agencies often use a couple:
- 998361 advertising services: campaign management, ad creative, media planning
- 998371 market research: audience research, surveys, competitor studies
- 998313 or 998319 where the work is mainly technical, such as analytics implementation or martech integration
The FIRA your bank issues carries an RBI purpose code. P1007 covers advertising, trade fair and market research. If a client pays for technical work, a software or IT code may fit better. Confirm SAC with your CA and purpose code with your bank. Our SAC code finder lets you search by service description.
Consistency matters more than perfection here. If your invoice says advertising, your FIRA says advertising and your EDF row says advertising, matching goes through. When one of the three says something else, expect a question.
A worked month: Saffron Reach Digital
Saffron Reach Digital LLP, a Jaipur agency, has five foreign clients. In November 2026 it raises:
| Invoice | Client | Country | Description | Currency | Amount |
|---|---|---|---|---|---|
| SRD/26-27/140 | Outdoor gear retailer | USA | Paid search retainer, Nov | USD | 3,500 |
| SRD/26-27/141 | Same | USA | Ad spend recharged at cost, Nov | USD | 8,200 |
| SRD/26-27/142 | Skincare brand | UK | SEO and content retainer, Nov | GBP | 2,400 |
| SRD/26-27/143 | SaaS startup | Germany | Product launch campaign, phase 1 | EUR | 6,000 |
| SRD/26-27/144 | Travel company | UAE | Social media management, Nov | AED | 9,500 |
One EDF lists all five rows, due by 30 December 2026. Mode of delivery: Internet. Mode of realisation: Others. The ad-spend recharge sits on its own row so the bank and the CA can see it clearly.
Each invoice is comfortably under ₹10 lakh, so once paid, Saffron Reach can close them through a periodic realisation declaration rather than sending FIRAs invoice by invoice.
Retainers, late payers and the nine-month window
Agencies live on retainers, and retainer clients develop habits. A client who always pays 45 days late is fine. A client who quietly stops paying is a problem, because each unpaid invoice keeps its own nine-month deadline.
Build a simple rule into your month-end routine:
- List every unpaid export invoice older than 90 days.
- Send a polite reminder; our post on invoice reminder emails has templates.
- At six months, escalate and decide whether to agree a reduced amount (with a credit note) or to seek an extension.
- Before nine months, ask your AD bank for an extension with reasons if the money is genuinely coming.
GST and LUT for agencies
Export of services is zero-rated. Most agencies export under an LUT filed on Form GST RFD-11, printing "Supply meant for export under LUT without payment of IGST" on each export invoice.
Two agency-specific cautions, both for your CA:
- Intermediary risk. If you arrange services supplied by others (for example, placing ads with platforms on behalf of the client as their agent), there is a question whether you are an intermediary for GST, which affects whether the supply qualifies as an export.
- Place of supply. Confirm it is outside India for each type of work, especially events or on-ground activations.
The EDF does not change any of this; it is a FEMA declaration, separate from GST. This article is general information, not legal or tax advice.
A short agency checklist
- Keep fees and recharges on separate invoices or at least separate lines.
- Use the same service description across invoice, EDF and any purpose-code request.
- Check each FIRA's purpose code within a week of receipt.
- File the EDF in the first half of the following month, not on the last day.
- Track every retainer invoice's realisation date, not just the client balance.
Frequently asked questions
Do digital marketing agencies need to file the EDF?
Yes, if the agency is a proprietorship, firm, LLP or company exporting services to foreign clients. It files one EDF per month with its AD bank listing every export invoice. Individual freelancers should check RBI's 7 October 2026 position and their bank's guidance.
Should ad spend recharged to a client go on the EDF?
If you invoice the foreign client for it, that invoice is part of your export billing and belongs on the EDF as its own row. Whether it is part of your taxable value for GST is a separate question to settle with your CA.
Which purpose code should a marketing agency use?
P1007 covers advertising, trade fair and market research, which suits most campaign and media work. Technical work such as analytics builds may suit an IT code instead. Confirm with your bank before the payment arrives if you can.
Can I combine all my clients on one EDF?
Yes. One EDF per month can include invoices to any number of foreign clients in any countries. Each invoice is a separate row with its own client, currency and amount.
What if a client pays three retainers in one payment?
The bank matches the single payment against the three invoice rows. Send the bank matching instructions listing the invoices covered, and note it in your register so you can close each entry.
Bottom line
For agencies, the EDF is simply your monthly invoice run viewed through a FEMA lens. Keep invoice types clean, codes consistent and late payers on a short leash. Build each month's form in minutes 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.