Chartered accountants who do bookkeeping, tax or advisory work for foreign clients are exporting services, and a CA firm or LLP should assume it must file the monthly EDF with its AD bank. A sole practitioner billing in their own name is in a greyer zone: on 7 October 2026 RBI said individuals providing services abroad are not required to report, but the Regulations have not been amended and FAQs are pending, so ask your bank. Many CAs will also be fielding this question from clients, which is a good reason to get your own practice in order first.
Key takeaways
- Partnership firms and LLPs of CAs should treat the EDF as applicable and file monthly.
- A sole practitioner may fall within RBI's 7 October 2026 statement on individuals, but the position is not settled until RBI's FAQs arrive.
- Typical codes: SAC 998222 (accounting and bookkeeping) and purpose code P1005 (accounting, auditing, bookkeeping and tax consulting). Confirm with your bank.
- One EDF per month covers all your export invoices; it is due within 30 days from month-end, or on or before payment for non-software services.
- The EDF is separate from your firm's own GST and income-tax position.
Who in the profession is covered
The 2026 Regulations, in force from 1 October 2026, apply to exports of services. The open question is individuals. At RBI's policy press conference on 7 October 2026, the Governor said individuals providing services abroad are not required to report, and the Deputy Governor said personal-contract transactions are outside the reporting requirement. RBI said it would issue FAQs. The Regulations' text has not changed yet.
How that applies to CAs depends on how you practise:
| Form of practice | Likely position | Practical step |
|---|---|---|
| Sole practitioner, billing in own name | Possibly within the individuals statement | Confirm with your bank; keep records ready either way |
| Sole proprietorship firm with a firm name and current account | Uncertain; safer to treat as covered | File, or get your bank's written view |
| Partnership firm of CAs | Covered | File monthly |
| LLP of CAs | Covered | File monthly |
| Company providing accounting/outsourcing services (not a CA firm as such) | Covered | File monthly |
The middle row is the one that will cause debate. A CA practising in a firm name is legally the same person as the proprietor, but the bank sees a business account and business invoices. Until the FAQs settle the point, the safer course is to file. It costs a few minutes a month.
The codes that usually fit
Accounting work for foreign clients has unusually clear codes compared with many professions:
- SAC 998222 covers accounting and bookkeeping services. Tax consulting, auditing and advisory may fit other codes in the 9982 group; confirm the right one for each service line.
- Purpose code P1005 covers accounting, auditing, bookkeeping and tax consulting services. Business and management consultancy may sit under P1006 instead.
You know the GST code mechanics better than most, but it is still worth confirming the purpose code with your bank, since that is what appears on the FIRA and what the bank matches against the EDF.
Worked example: Mehta Sanghvi & Associates LLP
Mehta Sanghvi & Associates LLP in Ahmedabad provides outsourced bookkeeping and US tax return preparation support to two CPA firms in the US, plus month-end close support to a small UK company.
October 2026 invoices:
| Invoice | Client | Service | Currency | Amount |
|---|---|---|---|---|
| MSA/EX/221 | US CPA firm A | Bookkeeping, October | USD | 5,600 |
| MSA/EX/222 | US CPA firm B | Tax return preparation support, 40 returns | USD | 8,000 |
| MSA/EX/223 | UK company | Month-end close support | GBP | 1,800 |
One EDF for October, three rows, two countries. At illustrative rates (USD ₹84, GBP ₹110), the total is ₹4,70,400 + ₹6,72,000 + ₹1,98,000 = ₹13,40,400. The designated partner signs Part 4. Because accounting is a service other than software, the LLP may file within 30 days from month-end (by 30 November 2026) or on or before the date payment is received, whichever suits.
All three invoices are below ₹10 lakh, so the bank may close EDPMS entries on a periodic realisation declaration. The LLP agrees with its bank to submit one each quarter.
A note for CAs advising clients
If you handle compliance for exporter clients, you will be asked about the EDF constantly. A few points worth holding on to:
- The EDF is a FEMA declaration to the AD bank. It does not change GST or income tax.
- One EDF per month, one row per invoice, due within 30 days of month-end (October 2026 invoices by 30 November 2026).
- Realisation within 9 months of invoice date for services, 12 months for rupee invoices.
- For invoices up to ₹10 lakh, a periodic declaration can close EDPMS entries.
- Banks set their own submission channels. Do not tell a client "HDFC wants X" unless the bank has said so.
Our article on how CAs can manage monthly EDFs for multiple clients covers practice workflows.
Invoicing hygiene for your own practice
Your own export invoices should be the model you would want from clients:
- Firm name, address, GSTIN and PAN.
- Client's legal name, address and country.
- Invoice number in an unbroken series, date, currency, description, SAC.
- LUT wording if you export under LUT: "Supply meant for export under LUT without payment of IGST".
- Bank details for the account where you want the money to land, since that bank receives your EDF.
Our export invoice generator produces a compliant layout quickly.
FIRA, GST and income tax
Ask your bank for a FIRA or inward remittance advice for every receipt, and check the purpose code reads P1005 (or whatever you agreed). Your exports are zero-rated supplies if the Section 2(6) IGST conditions are met. Income from foreign clients is taxable in India in the usual way. If a client withholds tax abroad, foreign tax credit and Form 67 may come into play.
This is general information, not legal or tax advice.
Frequently asked questions
Does a sole practitioner CA need to file the EDF?
Possibly not, given RBI's 7 October 2026 statement that individuals providing services abroad are not required to report. But the Regulations have not been amended and FAQs are pending, so check with your bank and keep records ready.
Is a CA partnership firm or LLP required to file?
Yes, assume so. Partnerships and LLPs exporting services should file a monthly EDF with their AD bank listing every export invoice raised in the month.
Which purpose code applies to accounting services for foreign clients?
P1005 covers accounting, auditing, bookkeeping and tax consulting services. Management consultancy may fall under P1006. Confirm with your bank for each service line.
Can the EDF be filed when the client pays instead of month-end?
For services other than software, the EDF may be submitted on or before the date payment is received, as an alternative to the 30-days-from-month-end deadline. Use whichever works for your billing cycle.
Does filing the EDF change my firm's GST position?
No. The EDF is a FEMA declaration. Your exports remain zero-rated for GST if the Section 2(6) conditions are met, and your LUT and returns continue as before.
Bottom line
CA firms and LLPs should file monthly; sole practitioners should confirm with their bank until RBI's FAQs arrive. Prepare your own EDF on the free EDF form generator and use the purpose code finder to double-check codes.
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.