EDF for Software Development Companies: Export Declaration Guide

A software development company that bills foreign clients now declares all of a month's export invoices on one Export Declaration Form, ticking "Software" as the type of export. The EDF is due within 30 days from the end of the invoice month and goes to your AD bank or STPI, or to the Development Commissioner if you are an SEZ unit. The hard part is rarely the form; it is translating time-and-material sheets, milestone invoices and support retainers into clean Part 2B rows every month.

Key takeaways

• Tick "Software" at field 1.1 and "Internet" at field 1.4 for code delivered online.
• File with your AD bank or STPI (non-SEZ), or the SEZ Development Commissioner (SEZ units). STPI certification is no longer mandatory.
• Every invoice raised in the month is one Part 2B row, whatever the billing model.
• SAC 998314 (IT design and development) or 998313 (IT consulting and support) are common; purpose codes P0802 or P0807 often apply. Confirm both.
• Realisation is 9 months from each invoice date; LUT and GST work exactly as before.

Billing models and how each lands on the EDF

Software firms rarely bill one way. A typical mid-sized company mixes three or four models, and each behaves slightly differently on the form.

The rule is simple even when the billing is not: the invoice date decides the EDF month. A November invoice for October's timesheets belongs on the November EDF, due 30 December 2026. Our article on clubbing all client invoices in one EDF shows how a single form handles many clients.

Codes: SAC and purpose codes, hedged

Two code sets matter, and they serve different systems.

SAC (for GST and the Part 2B column). Development work is often classified under 998314 (IT design and development services). Support, consulting and managed services may sit under 998313 (IT consulting and support) or 998319 (other IT services). Hosting fits 998315. Where a contract bundles several services, your CA should decide the principal supply.

Purpose codes (on the inward remittance). P0802 covers software consultancy and implementation; P0807 covers off-site software exports. Which one your bank applies depends on how it reads the payment and your contract. Tell the bank what the work is, and check each FIRA. Our guide to P0802 vs P0807 explains the difference.

Neither code is decided by the EDF itself, but inconsistency between your invoice, your EDF and your FIRA invites questions.

Worked example: one month at a 60-person firm

Quillstack Technologies Pvt Ltd, a Kolkata company with an STPI registration, banks with an AD bank and decided to file its EDF there. In October 2026 it raised:

Five rows went into Part 2B, each with its own currency, amount and contract reference. Field 1.22 showed the total in rupees using the rates Quillstack applied consistently. The EDF was signed by an authorised director and submitted on 21 November 2026, nine days before the due date.

Note row 1: the September dedicated-team invoice is on the October EDF because it is dated 1 October. Rows 1, 2 and 5 are each above ₹10 lakh, so they will need FIRAs and matching instructions to close. Rows 3 and 4 may close on a periodic realisation declaration once paid.

Realisation and collections

Each invoice must be realised in full within 9 months from its own date; 12 months if invoiced in rupees. For software firms, three situations cause most trouble:

• Disputed milestones. If a client withholds payment pending acceptance, track the 9-month date and request an extension from your AD bank before it lapses.
• Credit notes. If you issue a credit note for downtime or a discount, keep it linked to the original invoice and explain the reduced realisation to the bank.
• Intra-group billing. If you bill a foreign parent or affiliate, the same EDF and realisation rules apply.

GST and LUT

Software exports are zero-rated supplies when the Section 2(6) IGST conditions are met. Most firms export under LUT, filed in Form GST RFD-11, and print "Supply meant for export under LUT without payment of IGST" on invoices. The EDF does not change your GST or income-tax obligations; it is a FEMA declaration. Keep invoice numbers identical across your GST returns, EDF rows and bank matching letters so reconciliation is mechanical.

This is general information, not legal or tax advice.

Frequently asked questions

Should software companies file the EDF with STPI or the AD bank?

Outside an SEZ, either is allowed. AD banks are now specified authorities on par with STPI, and STPI certification is no longer mandatory. Many companies choose the AD bank because that is where payments land and matching happens.

Do I tick "Software" or "Services" on the EDF?

For software exports, tick "Software" at field 1.1. If a month mixes software development with clearly non-software services, ask your AD bank how it prefers the form completed.

How do I declare a T&M invoice for last month's work?

Declare it on the EDF for the month in which the invoice is dated, not the month the work was done. An invoice dated 3 November for October timesheets goes on the November EDF.

Can one EDF include clients in several countries and currencies?

Yes. One EDF per month covers all service export invoices to one or more recipients. Each row in Part 2B carries its own country and currency.

Are annual maintenance invoices declared in full up front?

The invoice is declared in the month it is raised, at its full value. Realisation is tracked against that invoice date, so make sure the client pays within 9 months or seek an extension.

Bottom line

For a software company, the EDF becomes painless once your billing data maps cleanly to Part 2B: one invoice, one row, one month. Settle your codes and channel once, then repeat. Build this month's form with our free EDF form generator, and check due dates on the EDF due date table.