A strategy, operations or HR consulting firm in India that bills clients abroad must list those invoices on a monthly EDF from 1 October 2026. For consultancies, the likely codes are SAC 998311 (management consulting) and purpose code P1006 (business and management consultancy and PR), both to be confirmed with your CA and bank. The real work is mapping consulting fee structures (phases, retainers, success fees, expenses) onto Part 2B rows without creating mismatches later.
Key takeaways
- One EDF per month lists every foreign invoice raised that month, due within 30 days from the end of the month.
- Phase fees, retainers and success fees each become ordinary Part 2B rows in the month they are invoiced.
- Success fees create long, uncertain receivables. Invoice them only once earned, then watch the 9-month realisation clock.
- Travel and out-of-pocket expenses billed to clients raise a reimbursement question. Agree a treatment with your CA and bank.
- Firms (companies, LLPs, partnerships, proprietorships) are covered. Individual consultants on personal contracts have a separate position after RBI's 7 October 2026 statement.
Consulting fee structures, mapped to the EDF
| Fee structure | Typical example | EDF treatment | Risk to manage |
|---|---|---|---|
| Fixed fee by phase | Diagnostic, design, implementation phases billed at sign-off | One row per phase invoice | Phase sign-off delayed, invoice delayed |
| Monthly retainer | Advisory board support at a fixed monthly fee | One row each month | Few; very predictable |
| Time and materials | Consultant days × day rate, billed monthly | One row per monthly invoice | Disputed timesheets lead to short payment |
| Success or performance fee | Percentage of savings or of a deal value | One row when invoiced | Long realisation, disputes over calculation |
| Expenses at actuals | Flights, hotels, per diems for on-site work abroad | Separate line or invoice; treatment to agree | Reimbursement question |
The EDF only cares about invoices. A twelve-month engagement does not need its own EDF; it simply shows up as a row in each month where you invoice it.
Codes for consulting work
For most general management consulting, SAC 998311 is the natural code, and P1006 is the purpose code banks commonly use for business and management consultancy and public relations. Our article on SAC codes for consulting services explains the neighbouring codes.
Watch for engagements that drift into other categories:
- IT strategy that becomes system implementation may fit IT consulting (SAC 998313) and P0802.
- Market research studies may sit under SAC 998371 and P1007.
- Accounting and tax advisory may fit P1005.
If a single client contract mixes these, describe the main service accurately and ask your CA how to code it. Keep the purpose code consistent with the invoice description; mismatches cause friction when the bank matches receipts. The purpose code finder helps you shortlist.
Mode of delivery when consultants travel
Field 1.4 asks how the service was delivered. Remote work, reports and video workshops point to "Internet". Consulting often involves consultants on site with the client abroad for weeks. That is still an export of services, but "Internet" may not describe it well, and "Others" may be more accurate. Ask your bank which it prefers for on-site engagements and use it consistently.
A worked example
Northstar Strategy Partners LLP in Bengaluru has three foreign engagements. Its February 2027 invoices:
| Invoice | Client | Basis | Currency amount | INR value |
|---|---|---|---|---|
| NSP/27/014 | Arden Logistics Ltd (UK) | Phase 2: network design, fixed fee | GBP 22,000 | ₹23,40,000 |
| NSP/27/015 | Qamar Holdings (UAE) | Advisory retainer, February | AED 30,000 | ₹6,82,000 |
| NSP/27/016 | Arden Logistics Ltd (UK) | Travel and accommodation, Phase 2, at actuals | GBP 3,100 | ₹3,30,000 |
Northstar files one EDF with three rows. February invoices are due by 30 March 2027. The partners treated the expense invoice as a separate row because the client pays it as a separate invoice, after discussing it with their CA. Our article on reimbursement of expenses covers the arguments on both sides.
Phase 2 exceeds ₹10 lakh, so closing its EDPMS entry will need the invoice, FIRA and matching instructions. The retainer and expense invoices can be covered by a periodic realisation declaration once paid.
The success fee wrinkle
Northstar also has a success fee with Arden: 8% of first-year savings, measured after twelve months. The firm will not invoice it until the savings are agreed. That is the right approach for the EDF too: invoicing a success fee early starts the 9-month realisation clock on money that may be disputed for months.
Realisation for consulting receivables
Services must be realised within 9 months from each invoice date (12 months if invoiced in rupees). Consulting clients often pay well, but large corporate clients can have long approval cycles, and disputed timesheets or success-fee calculations can stall payment.
| Situation | What to do |
|---|---|
| Client pays short because of a disputed day | Issue a credit note if you concede; inform the bank so the entry closes at the right value |
| Phase sign-off delayed, invoice not yet raised | Nothing on the EDF yet; the clock has not started |
| Large invoice approaching month 8 unpaid | Chase the client, then ask your bank for an extension with reasons before the deadline |
| Client withholds tax abroad | Bank receives less; keep the withholding certificate for your CA and the bank |
GST, LUT and invoicing
Consulting for an overseas client is generally a zero-rated export where all five Section 2(6) IGST Act conditions are met. Most firms export under LUT, with invoices stating "Supply meant for export under LUT without payment of IGST". Our invoice format for consulting services lists the fields to include.
The EDF does not change GST or income-tax obligations. This article is general information, not legal or tax advice.
Frequently asked questions
What SAC code should a management consulting firm use on the EDF?
SAC 998311 covers management consulting and is the usual starting point. If the engagement is really IT consulting, market research or accounting advisory, a different code may fit better. Confirm with your CA.
Which purpose code applies to consulting fees from abroad?
P1006 (business and management consultancy and PR) is commonly used. Agree it with your bank so inward remittances are tagged consistently, and correct any receipt coded differently.
How do success fees appear on the EDF?
As an ordinary Part 2B row in the month you invoice them. Invoice only once the fee is earned and agreed, because the 9-month realisation period starts on the invoice date.
Do on-site engagements abroad count as service exports?
Generally yes, if the conditions are met. For field 1.4, ask your bank whether it prefers "Others" or "Internet" for work performed on the client's premises abroad.
Do solo consultants need to file the EDF too?
RBI said on 7 October 2026 that individuals providing services abroad are not required to report, with FAQs to follow. Consultants operating through a firm, LLP or company should file. See our guide for independent consultants.
Bottom line
For a consulting firm, the EDF is a monthly list of phase fees, retainers and other invoices, coded consistently and matched to receipts. Invoice success fees only when earned and agree an expenses policy early. The free EDF form generator builds the monthly form from your invoice list.
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.