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  4. EDF for Game Development Studios: Export Declaration Guide
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EDF for Game Development Studios: Export Declaration Guide

An Indian game studio that builds games, art or features for overseas publishers is exporting services, and from 1 October 2026 it declares those exports on a monthly EDF to its AD bank (or STPI for software). Work-for-hire and co-development invoices go on the EDF; your own game's sales through app stores are a different kind of income and need a separate conversation with your bank and CA. This guide covers the first case in detail.

Key takeaways

  • Work-for-hire for foreign publishers, co-development, porting, QA and art outsourcing are service exports that go on the EDF.
  • Revenue from selling your own game through global stores is not a typical client invoice. Ask your bank how it wants that treated.
  • Each milestone or monthly invoice is one row in Part 2B. One EDF covers the whole month.
  • Likely SAC codes: 998314 for game development, others for art or QA. Likely purpose codes: P0807 or P0802 for development. Confirm both.
  • Milestone acceptance delays are the biggest realisation risk. Watch the 9-month clock.

What kind of studio are you?

Game studios earn money in very different ways, and the EDF fits some of them neatly and others awkwardly.

Revenue stream Is it a service export invoiced to a client? EDF approach
Co-development for a foreign publisher Yes Monthly EDF, one row per invoice
Porting a title to new platforms for a client Yes Same
Art and animation outsourcing Yes Same
QA and localisation testing for a client Yes Same
Live-ops support retainer Yes Same
Your own game sold via app stores or PC stores Not a typical client invoice Ask your bank and CA
Advertising revenue from ad networks in your game Unclear Ask your bank and CA
Publisher advance against royalties Depends on contract Ask your bank and CA

The rest of this guide focuses on the "yes" rows, which is where most Indian studios earn foreign income.

Picking the export type and delivery mode

In field 1.1, game code delivered to a client is generally software, which means you may file the EDF with your AD bank or with STPI if you are outside an SEZ. Pure art or animation work may be better described as services. If your studio does both, discuss the split with your CA and bank.

Field 1.4, mode of delivery, is almost always "Internet": builds, assets and test reports go out through repositories, file transfer and cloud storage.

Codes that often fit

Work SAC (confirm with CA) Purpose code (confirm with bank)
Game programming, co-dev, porting 998314 IT design & development P0807 off-site software exports, or P0802
Technical support for a live game 998313 or 998319 P0802
Concept art, 2D/3D assets A design or creative code, confirm with CA Confirm with bank
QA testing 998319 or as advised Confirm with bank

Art outsourcing is where codes are least settled. Ask your CA which SAC best describes your art services, and ask your bank which purpose code it expects on receipts. Then use the same pair every time. Our purpose code finder lists the common options.

How studio billing maps to the EDF

Milestone billing

Publishers usually pay on milestones: vertical slice, alpha, beta, gold. You invoice when a milestone is delivered or accepted, depending on the contract. Each invoice appears on the EDF for the month of its invoice date.

Monthly team billing

Co-dev contracts often bill a monthly team rate: so many developers, artists and testers at agreed day rates. That is one invoice a month per client, one row per invoice.

Change requests

Extra scope is often billed separately. A change-request invoice is its own row, even if it goes to the same publisher in the same month.

Advances

If a publisher pays an advance before work starts, note it. When the invoice is raised, mention the advance in remarks and, in Part 4, show the value as received where that is true. See our article on milestone billing for export projects.

Worked example: Monsoon Pixel Studios

Monsoon Pixel Studios Pvt Ltd in Pune does co-development and art for two publishers: one in Finland, one in Japan.

In October 2026:

  • Finnish publisher: monthly team invoice, EUR 31,000, dated 31 October (SAC 998314).
  • Japanese publisher: art milestone 3 accepted, invoice JPY 2,400,000, dated 15 October.
  • Japanese publisher: change request for extra character skins, JPY 450,000, dated 28 October.

One EDF for October, three rows, two countries. At illustrative rates (EUR ₹92, JPY ₹0.56), the totals are ₹28,52,000, ₹13,44,000 and ₹2,52,000, giving ₹44,48,000 in field 1.22. Due by 30 November 2026, to the AD bank where both publishers pay.

The first two invoices exceed ₹10 lakh each and will need payment evidence when the bank closes their EDPMS entries. The change request is under ₹10 lakh and can be covered by a periodic realisation declaration if the bank allows.

The milestone acceptance problem

Studios run into a specific realisation risk. A milestone is delivered and invoiced, but the publisher disputes quality, delays acceptance, or puts the project on hold. Payment drifts.

For services, full export value must be realised within 9 months from the invoice date. If you are approaching that limit, ask your AD bank for an extension, with reasons and supporting emails, before the date passes. Our realisation extension request letter provides a format.

Two habits help:

  • Invoice on acceptance, not delivery, if your contract allows. It shortens the gap between invoice and payment.
  • Keep acceptance emails with each invoice. They are your best evidence if the bank asks why payment is late.

If a publisher cancels a milestone you already invoiced, issue a credit note and tell your bank. Do not leave the original entry hanging.

GST and LUT

Game development for a foreign publisher, delivered from India and paid in foreign currency, is typically a zero-rated export if it meets the Section 2(6) IGST conditions. Export under LUT and print the LUT wording on your invoices. The EDF does not change your GST or income-tax position.

Studios that sell their own games to Indian players also have domestic GST matters; keep those separate from the export side. This is general information, not legal or tax advice.

Frequently asked questions

Does a game studio need to file the EDF for publisher work?

If you are a company, LLP or firm providing development, art, porting or QA to a foreign publisher, yes, plan to file monthly. Each invoice for that month becomes a row on one EDF.

Do app store payouts go on the EDF?

Store payouts for your own game are not ordinary client invoices for services, and the EDF format is built around invoices. Ask your AD bank how it wants such receipts handled and get your CA's view on classification.

Which purpose code should a game development studio use?

Development work is commonly coded P0807 (off-site software exports) or P0802 (software consultancy/implementation). Art and QA may fit other codes. Confirm with your bank and keep it consistent.

How do I show a publisher advance on the EDF?

The EDF lists invoices. When you raise the invoice against which the advance applies, note the advance in remarks and indicate in Part 4 that the value has been received, to the extent it has.

What if a milestone invoice is unpaid for months?

Track the 9-month realisation date. If payment may slip beyond it, ask your AD bank for an extension with reasons before the deadline, and keep correspondence with the publisher on file.

Bottom line

For game studios, every publisher invoice becomes a row on a monthly EDF, and milestone discipline protects your realisation window. Prepare the form with the free EDF form generator and keep your EDF due dates on the studio calendar.

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.