If you earn affiliate commissions from foreign merchants or networks as an individual, RBI's statement of 7 October 2026 suggests you do not need to file: the Governor said individuals providing services abroad are not required to report, and RBI promised FAQs. If your affiliate sites run as a proprietorship, LLP or company, assume the EDF applies to those foreign commissions until the FAQs say otherwise, and ask your bank how it wants commission income presented.
Key takeaways
- Individuals on personal arrangements have RBI's 7 October 2026 statement in their favour. The Regulations' text has not changed yet.
- Affiliate businesses run through an entity should plan to file a monthly EDF for foreign commissions.
- Commissions often arrive without an invoice from you. Ask your bank how to present them; some affiliates raise a monthly invoice matching each network statement.
- Small, frequent payouts suit the ₹10 lakh realisation declaration for closing EDPMS entries.
- GST treatment of affiliate commissions can be tricky (the intermediary question). Speak to your CA before assuming zero-rating.
Is an affiliate commission even an export of services?
The EDF regime covers exports of services, and the fit for affiliate marketing is less obvious than for, say, software development. You promote a merchant's product, a customer buys, and the merchant or network pays you a share. In substance you are providing marketing services to a foreign business, which is why many affiliates receiving foreign commissions treat them as service export income.
That said, nothing in the facts we rely on addresses affiliate income specifically. Treat the analysis below as practical guidance, not a settled position, and check it with your bank and CA. This is general information, not legal or tax advice.
Individual or business: the line that matters
| Your set-up | EDF position | What to do |
|---|---|---|
| Individual; blog or channel in your own name; payouts to savings account | RBI said individuals are not required to report | Confirm with your bank until FAQs arrive |
| Individual, GST-registered, no trade name | Grey area | Ask your bank; keep invoice-quality records |
| Proprietorship with a brand name, current account, GSTIN | Assume covered | File monthly until FAQs clarify |
| LLP or company running a portfolio of sites | Covered | File monthly |
On 7 October 2026, the Governor said individuals providing services abroad (examples given included tutoring and small software work) are not required to report, and the Deputy Governor said personal-contract transactions fall outside the reporting requirement. A solo affiliate with a single niche site fits that description comfortably. A media company with editors, a content calendar and ten sites does not. If you also do freelance campaign work, see our related piece on whether freelance marketers need to file the EDF.
The invoice problem
The EDF's Part 2B is built around invoices: invoice number, invoice date, recipient, currency, amount. Affiliate income often works the other way round. The network or merchant generates a statement, approves commissions after a return window, and pays you. You may never raise an invoice.
Two approaches are seen in practice:
- Raise your own monthly invoice to each network or merchant, matching the approved commission statement. This gives you an invoice number and date for Part 2B and makes FIRA matching easy.
- Use the network's statement as the reference and ask your bank whether it will accept that in place of an invoice.
We do not have verified guidance on which banks prefer. Ask your AD bank in writing before your first EDF.
Timing: approval versus payment
Networks often approve commissions weeks after the sale, then pay on a schedule. The EDF trigger is the invoice date, so if you invoice on approval, the EDF month follows the approval month, and the 9-month realisation clock starts from that invoice date. That is usually comfortable for affiliate payouts, which tend to arrive well within nine months.
A worked example
Blue Kettle Reviews is a proprietorship in Dehradun run by Sanjay, with a trade name, current account and GSTIN. It earns from several foreign programmes. Approved commissions for November 2026:
| Payer | Statement period | Currency | Amount | INR value |
|---|---|---|---|---|
| Network A (USA) | October sales, approved November | USD | 1,840 | ₹1,54,000 |
| Merchant B (UK) | October sales | GBP | 620 | ₹66,000 |
| Network C (Netherlands) | October sales | EUR | 910 | ₹84,000 |
| Merchant D (Canada) | October sales | CAD | 1,150 | ₹69,000 |
Sanjay raises four invoices dated 30 November 2026, one to each payer, matching the approved amounts. He files one November EDF with four Part 2B rows and ₹3,73,000 in field 1.22, due by 30 December 2026.
Every invoice is well under ₹10 lakh. Once the payouts arrive, Sanjay gives his bank a quarterly realisation declaration covering all of them, instead of sending evidence invoice by invoice.
FIRAs and purpose codes
Affiliate payouts often arrive from payment processors or network entities rather than the merchant. That makes the FIRA more important: it records who actually sent the money, the currency and the purpose code. Collect one for every payout and file it with the matching statement or invoice.
Purpose codes for commission income are not obvious. Marketing-related codes such as P1007 (advertising, trade fair, market research) may be suggested, but your bank decides how it tags receipts. Use the purpose code finder to prepare, then agree the code with your bank and keep it consistent.
GST: the intermediary question
If you are GST-registered, do not assume affiliate commissions are automatically zero-rated exports. Export of services requires five conditions, including that the place of supply is outside India. Some advisers view affiliate referrals as resembling intermediary services, where the place of supply rules can differ. Others see them as marketing services to the foreign merchant. The answer can depend on your contracts and how you work. Get a written view from your CA before deciding.
Income tax reminder
Affiliate commissions are taxable income for a resident, whether paid by an Indian or foreign merchant, and whether or not you file an EDF. Keep statements, FIRAs and expense records. Our guide to income tax on foreign income covers presumptive schemes and foreign tax credits.
Frequently asked questions
Do individual affiliate marketers need to file the EDF?
RBI said on 7 October 2026 that individuals providing services abroad are not required to report, and that FAQs would follow. The Regulations' text has not yet changed, so confirm with your bank. Individuals earning affiliate commissions in their own name are in a much stronger position than businesses.
My affiliate business is a proprietorship. Should I file?
Assume yes until RBI's FAQs say otherwise, especially if you have a trade name, current account and GSTIN. File one EDF a month listing each foreign commission invoice or statement your bank accepts.
What if I never raise invoices to affiliate networks?
Ask your bank whether it will accept network statements as the reference. Many affiliates find it simpler to raise a monthly invoice to each network matching the approved commission, which gives a clean Part 2B row and an easy FIRA match.
Which purpose code applies to affiliate commissions?
There is no single obvious code among the common ones. Marketing-related codes may be suggested, but your bank decides how it tags the receipt. Agree it in advance and correct mis-tagged payouts promptly.
Are foreign affiliate commissions zero-rated under GST?
Not automatically. Zero-rating needs all five export conditions, and the place of supply for affiliate-type services can be debatable. Ask your CA before treating them as exports.
Bottom line
Solo affiliates earning in their own name can likely skip the EDF, pending RBI's FAQs and a word with their bank. Affiliate businesses should file monthly, using invoices that match network statements. When you are ready, the free EDF form generator turns a month of commission statements into a ready-to-sign form.
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.