A web design agency billing clients abroad files one EDF a month to its AD bank, listing every foreign invoice raised that month — project milestones, retainers, maintenance and hosting alike. Mode of delivery is almost always Internet, the services usually sit in the IT design and development family for SAC purposes, and the money must arrive within 9 months of each invoice date. The tricky parts are agency-specific: mixed invoices, change requests and clients who pay one big sum for several bills.
Key takeaways
- Every foreign invoice raised in a month goes into that month's EDF, due 30 days after month end.
- Mode of delivery (field 1.4) is Internet for work delivered online.
- Website builds commonly use SAC 998314; hosting fits 998315 — confirm with your CA.
- Purpose codes are set by the bank on the inward payment; check what yours applies.
- Export under LUT and print the LUT line on every export invoice.
How agency billing maps onto the EDF
Agencies rarely send one tidy invoice per client per month. A typical client might get a 40% deposit, two milestone bills, a change-request invoice and a monthly care plan. The EDF doesn't care about your billing model — it cares about invoices. Each invoice is one row in Part 2B, and all invoices dated in a month go on that month's form.
| Billing pattern | What goes on the EDF | Watch out for |
|---|---|---|
| Deposit + milestones | Each milestone invoice in the month it's raised | Deposit received before the invoice — see advances below |
| Monthly retainer / care plan | One row per monthly invoice | Don't skip months when the amount is small |
| Change requests | Separate row if separately invoiced | Reference the original project in the description |
| Hosting and domains | Row per invoice; consider a separate SAC line | Pass-through domain fees — ask your CA how to show them |
| Usage-based (e.g. per page, per hour) | Row per invoice | Attach timesheets to your own file, not necessarily the EDF |
Codes: SAC and purpose code
SAC code
Most website design and build work fits 998314 — IT design and development services. If you mainly advise on UX strategy, platforms or audits, 998313 (IT consulting and support) may be closer. Ongoing hosting you provide fits 998315 — hosting and IT infrastructure. Pure visual or brand design without development could fall under 998393 (other specialty design). These are judgement calls; your CA should confirm, and the SAC code finder helps you compare.
Purpose code
The purpose code is attached by the bank to each inward payment. Agencies doing web development commonly see codes in the software family (P0802 for software consultancy/implementation, P0807 for off-site software exports), while design-only or digital-advertising work may be coded differently. Ask your bank which code it applies, check the FIRA, and request a correction early if it doesn't fit.
Worked example: Indigo Grid Studio's November
Indigo Grid Studio LLP, a 12-person agency in Jaipur, works for clients in Australia, the US and the UK. In November 2026 it raised:
| Invoice | Client (country) | What for | Currency | Amount | Approx. INR |
|---|---|---|---|---|---|
| IGS/26/310 | Harbour Physio (Australia) | Milestone 2 — design sign-off | AUD | 4,500 | ₹2,48,000 |
| IGS/26/311 | Harbour Physio (Australia) | Change request — booking page | AUD | 900 | ₹50,000 |
| IGS/26/315 | Redwood Realty (USA) | Monthly care plan, November | USD | 650 | ₹54,000 |
| IGS/26/318 | Larkspur Bakeries (UK) | Final milestone — e-commerce launch | GBP | 6,200 | ₹6,82,000 |
| IGS/26/319 | Larkspur Bakeries (UK) | Annual hosting, Dec 2026–Nov 2027 | GBP | 480 | ₹53,000 |
One EDF, five Part 2B rows, total about ₹10,87,000, due 30 December 2026. Field 1.4 says Internet; 1.12 says Others (direct bank transfer). Each row carries the invoice number, date, currency, amount, net realisable value, a short description and the SAC.
In January, Larkspur pays GBP 6,680 in one transfer for both its invoices. Indigo Grid sends the bank a matching note splitting the payment between IGS/26/318 and 319. The Redwood care plan, the Harbour change request and the hosting invoice are each under ₹10 lakh, so they can be closed through Indigo Grid's quarterly realisation declaration.
Deposits and advances
Many agencies take a deposit before work starts. If the money arrives before you raise an invoice, you have an advance. The Regulations let services other than software file the EDF on or before the date payment is received — so one clean approach is to raise the deposit invoice first and declare it. Practices differ by bank and the software/non-software line can blur for web development. Ask your bank how it wants advances shown, and our article on EDF for advance payments sets out the options.
GST: zero-rating and LUT
Export of services is a zero-rated supply when the Section 2(6) IGST conditions are met: you're in India, the client is outside India, place of supply is outside India, payment comes in convertible foreign exchange (or INR where RBI permits), and you and the client aren't merely establishments of the same person.
Most agencies export under an LUT filed on Form GST RFD-11. Every export invoice should then say: "Supply meant for export under LUT without payment of IGST". Our export invoice generator prints that line, the SAC and both currency and INR values. The EDF itself doesn't change your GST or income-tax position — it's a separate FEMA declaration.
This is general information, not legal or tax advice.
Realisation: chasing the last milestone
The final milestone is where agencies get burned: the site is live, the client is happy, and the invoice drifts. Services must be realised within 9 months from the invoice date. Put a diary note at month three and month six for every unpaid export invoice. If a client is genuinely slow but will pay, your AD bank can extend the period on a reasoned request.
A simple habit helps: invoice the final milestone on launch day, not when you get round to it. The earlier the invoice, the clearer the timeline.
Frequently asked questions
Do web design agencies need to file an EDF every month?
Yes, if you raised any foreign invoices that month. One EDF covers all service exports of the month to one or more clients, and it's due within 30 days from the end of that month.
Which mode of delivery should a web agency choose on the EDF?
Internet, for design and development delivered online. Field 1.4 offers Air, Land, Sea, Post/Courier, Internet and Others; online delivery fits Internet.
What SAC code should a web design agency use?
Website design and development commonly uses 998314 (IT design and development). Hosting fits 998315, and pure graphic or brand design may fit 998393. Confirm the right code for each service line with your CA.
How do I declare a monthly website maintenance retainer?
Each monthly retainer invoice is a separate row in Part 2B of the EDF for the month it's raised. Small amounts still need declaring; they can often be closed later through the ₹10 lakh realisation declaration.
Can I put domain registration charges on the EDF?
If you invoice the client for them, they're part of the invoice and the invoice goes on the EDF. Whether pass-through costs should be shown separately on the invoice is a GST question for your CA.
Bottom line
For a web agency, the EDF is a monthly list of every foreign invoice, however small, with Internet delivery and consistent SAC codes. Build the list in the free EDF form generator and keep a matching note ready for every combined payment.
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.