An Indian SaaS company selling to overseas customers files one Export Declaration Form a month with its AD bank, listing every foreign invoice dated in that month. Since SOFTEX was withdrawn, software and SaaS exports go on the same single EDF as other services, due within 30 days from the end of the invoice month. The tricky part for SaaS is not the form; it is the invoice pattern, especially when you bill hundreds of small subscriptions.
Key takeaways
- SaaS exports are declared on the EDF, with type of export usually "Software" and mode of delivery "Internet".
- One EDF per month can cover every foreign invoice in that month. High-volume billing means many Part 2B rows, so ask your bank how it wants them presented.
- Likely SAC codes include 998315 (hosting and IT infrastructure) or 998314 (IT design and development), depending on what you actually supply. Confirm with your CA.
- Purpose codes such as P0807 (off-site software exports) or P0802 (software consultancy and implementation) often fit. Confirm with your bank.
- Realise each invoice within 9 months of its date, and keep your LUT current so exports go out without IGST.
Is SaaS "software" or "services" on the EDF?
Field 1.1 offers three choices: Goods, Services or Software. Most SaaS businesses tick Software, since what they sell is access to software delivered online. Where you also sell consulting, training or managed services, those invoices may sit more naturally under Services.
This choice has one practical effect. Exporters of services other than software may submit the EDF on or before the date payment is received, as an alternative to the monthly deadline. Software exporters should plan around the 30-day monthly deadline. Also, software exporters outside an SEZ may file with their AD bank or STPI; AD banks are now "specified authorities" on par with STPI and STPI certification is no longer mandatory.
Matching your invoice patterns to Part 2B
Each invoice is one row in Part 2B. Here is how common SaaS billing models translate:
| Billing model | Typical invoice | Part 2B treatment | Watch-outs |
|---|---|---|---|
| Annual subscription, enterprise | One invoice per customer per year | One row in the month of invoice | Large single rows; above ₹10 lakh needs full matching |
| Monthly subscription, mid-market | One invoice per customer per month | One row per customer each month | Many repeat rows; keep numbering clean |
| Usage or metered billing | Invoice after period ends, variable amount | One row per invoice, dated when raised | Invoice date, not usage period, drives the EDF month |
| Implementation or onboarding fee | Milestone invoices | One row per milestone invoice | May be Services rather than Software; check SAC |
| Self-serve card subscriptions | Many small invoices via a payment gateway | Potentially hundreds of rows | Ask the bank how it wants high volumes presented |
The last row deserves a direct conversation with your AD bank. The regulations say each invoice is a row in Part 2B, but how a bank prefers to receive several hundred rows, for example as an attached schedule, is a matter of its own published policy. Ask before your first big month, not after. Our deeper piece on SaaS subscriptions and usage-based billing covers the invoicing side.
Who is your AD bank when a gateway collects payments?
If enterprise customers pay by wire transfer into your current account, that bank is your AD bank. If card payments are collected by a cross-border payment gateway or aggregator and settled into your Indian account, the bank receiving the settlement is usually the one that will expect the EDF. Gateways differ in how they settle and what payment advice they provide, so check your provider's current India documentation and ask your bank which records it will accept as payment evidence. If you use Stripe, see our note on getting paid through Stripe.
Worked example: a mixed SaaS month
Ledgerly Cloud Pvt Ltd, Pune, sells accounting software to small firms in the UK, US and Singapore. Suppose that in November 2026 it raises:
- 2 annual enterprise invoices: GBP 18,000 and USD 24,000
- 46 monthly mid-market invoices averaging USD 650
- 1 implementation invoice: SGD 9,500
- Self-serve card subscriptions settled through a gateway: 210 small invoices totalling about USD 6,300
Its November EDF, due 30 December 2026:
- Part 1: type of export Software, mode of delivery Internet, AD code of the branch receiving wires and gateway settlements, mode of realisation Others.
- Part 2B: 2 + 46 + 1 rows for the larger invoices; for the 210 self-serve invoices, Ledgerly agrees in advance with its bank how to present them in a schedule.
- SAC: 998315 for subscriptions on its CA's advice; 998314 for the implementation work.
- Total value (1.22): roughly ₹76,00,000.
Each row has its own 9-month realisation clock. The GBP 18,000 annual invoice is above ₹10 lakh, so its closure needs invoice, FIRA and matching instructions. The small invoices can be closed on Ledgerly's periodic declaration under the ₹10 lakh rule if the bank agrees.
GST, LUT and the numbers that must agree
SaaS supplied to customers abroad can qualify as export of services, a zero-rated supply, if the five Section 2(6) IGST conditions hold: supplier in India, recipient outside India, place of supply outside India, payment in convertible foreign exchange (or INR where RBI permits), and not merely establishments of a distinct person.
Most SaaS exporters work under an LUT (Form GST RFD-11) and put "Supply meant for export under LUT without payment of IGST" on every export invoice. Selling to individual consumers abroad can raise different GST questions than B2B sales; discuss your customer mix with your CA. This article is general information, not legal or tax advice.
Make sure these agree, month after month:
- invoice register total for foreign customers;
- EDF field 1.22;
- export turnover in your GST return;
- inward receipts in your bank statements, net of gateway fees and charges.
Realisation discipline for subscription businesses
SaaS companies are used to watching churn and collections. Add one metric: invoices approaching nine months unpaid. A failed card retry or a disputed renewal can leave an annual invoice open for months. If a customer will pay late, ask the bank for an extension before the deadline. If a customer will never pay, the conversation with your bank is about closure, not silence.
Frequently asked questions
Do SaaS companies still need STPI after SOFTEX was withdrawn?
STPI certification is no longer mandatory. Software exporters outside an SEZ can file the EDF with their AD bank or with STPI, since AD banks are now specified authorities on par with STPI. Many SaaS companies find their bank simpler.
Which SAC code should a SaaS company use?
It depends on what you supply. Hosting and IT infrastructure services are commonly 998315, and IT design and development 998314, but subscription software can be classified differently depending on the facts. Confirm with your CA and use the same code on the invoice and the EDF.
Do I list every self-serve subscription invoice on the EDF?
The regulations treat each invoice as one row in Part 2B. For high volumes, ask your AD bank how it wants them presented, for example as an attached schedule, before you file.
What purpose code applies to SaaS receipts?
P0807 (off-site software exports) and P0802 (software consultancy and implementation) are common for software businesses, but the correct code depends on the service. Confirm with your bank and check each FIRA.
Does a usage-based invoice go on the EDF for the usage month or the invoice month?
The EDF month is driven by the invoice date. If October usage is invoiced on 2 November, that invoice belongs on the November EDF.
Bottom line
For a SaaS company, the EDF is a monthly reconciliation of your foreign billing, and it works best when your invoice data is clean. Generate your monthly form with the free EDF form generator, and check codes with the SAC code finder.
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.