A BPO or call centre serving foreign clients is a service exporter, and from 1 October 2026 it declares those exports on one EDF a month, filed with its AD bank within 30 days from the end of the invoice month. The tricky part for BPOs is not the form but the billing: per-seat, per-hour and per-minute invoices must each appear as a row in Part 2B, at the invoiced amount, with credits and penalties handled consistently. Get your invoice structure tidy and the EDF follows easily.
Key takeaways
- BPOs and call centres outside an SEZ file the EDF with their AD bank; SEZ units file with the Development Commissioner.
- Every invoice dated in the month is a separate row in Part 2B, regardless of the billing model.
- Mode of delivery is usually Internet; if service is delivered over dedicated telecom links, confirm what your bank expects.
- SAC and purpose codes depend on what you actually do (voice support, back office, IT helpdesk), so confirm them with your CA and bank.
- Service-level credits and penalties change what you realise; handle them through credit notes and NRV, not by quietly editing figures.
How BPO work fits the EDF
The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 treat customer support, back-office processing and similar outsourced work for foreign clients as service exports. A single EDF can cover all service exports of the month, to one or more clients, under Regulation 3(2)(a).
Most BPOs are outside SEZs and file with their AD bank. A number of larger operations sit inside SEZs and file with the SEZ Development Commissioner instead. If you have units in both, each follows its own route.
Delivery mode and category
Field 1.4 asks for mode of delivery. For services delivered online, Internet is the natural choice. Voice processes often run over internet-based telephony, which fits Internet too; if your delivery depends on dedicated circuits, ask your bank whether it prefers Internet or Others.
Field 1.5 asks for exporter category. Most non-SEZ BPOs are in the domestic tariff area; our article on category of exporter explains the options.
Billing models and how each appears in Part 2B
| Billing model | Typical invoice | EDF treatment |
|---|---|---|
| Per seat / per FTE per month | Fixed monthly amount per agent | One row per invoice; description notes number of seats |
| Per productive hour | Hours logged × rate | One row per invoice; hours in description or remarks |
| Per minute / per contact | Usage-based, varies monthly | One row per invoice at the billed amount |
| Per transaction (back office) | Volume × unit rate | One row per invoice |
| Set-up or transition fee | One-off | Separate row if separately invoiced |
| Service-level credit | Reduction for missed targets | Credit note; reflect in NRV and records |
The rule is simple: the EDF follows your invoices. If you invoice one client three times in a month, there are three rows.
SAC and purpose codes, with care
BPO work spans very different services, so there is no single correct code.
- SAC: IT helpdesk or technical support might sit near 998313 (IT consulting and support) or 998319 (other IT services). Pure customer care or back-office processing may fall under other support-service codes. Ask your CA to map each service line once, using our SAC code finder as a starting point.
- Purpose code: your inward remittances carry an RBI purpose code. IT-enabled support might attract a software-family code, while business support could fall under a different group. Confirm with your bank, and check the code on every FIRA.
Get these right at the start; changing them later means correcting many FIRAs.
A worked example
Northstar CX Solutions Pvt Ltd in Mohali runs two processes for foreign clients:
- Inbound customer care for a US retailer, billed per productive hour.
- Order processing for a UK marketplace seller, billed per transaction.
October 2026 invoices:
| Invoice | Date | Client | Basis | Amount |
|---|---|---|---|---|
| NCX/1026/01 | 31 Oct 2026 | US retailer | 3,840 hours × USD 9.50 | USD 36,480 |
| NCX/1026/02 | 31 Oct 2026 | UK seller | 21,000 orders × GBP 0.35 | GBP 7,350 |
| NCX/1026/03 | 15 Oct 2026 | US retailer | Training batch set-up | USD 2,500 |
Northstar files one EDF for October with three rows, due 30 November 2026. In November, the US client applies a service-level credit of USD 1,100 for missed answer-time targets. Northstar issues a credit note referencing NCX/1026/01, records USD 35,380 as the expected realisation, and notes the credit note number in the remarks when it updates its EDF register. If the bank asks, it explains the gap with the credit note.
The UK seller pays GBP 7,350 less intermediary bank charges; the FIRA shows the net amount, and Northstar reconciles the difference.
Realisation, the ₹10 lakh route and GST
Services must be realised within 9 months from the invoice date. BPO clients often pay on 30- to 60-day terms, so this is rarely tight, but disputes over hours or quality can drag. Track ageing monthly.
Many BPO invoices exceed ₹10 lakh. For those, the bank closes EDPMS entries on invoice, payment evidence and matching instructions. Smaller invoices, such as set-up fees, can be closed through a periodic declaration of realisation, which you can prepare with our realisation declaration tool.
On GST, export of services is zero-rated when the Section 2(6) IGST Act conditions are met. Most BPOs export under LUT and put "Supply meant for export under LUT without payment of IGST" on the invoice. Watch place of supply where a service is performed on goods or people located in India; that can change the answer. The EDF itself does not change GST or income tax.
This is general information, not legal or tax advice; confirm codes and GST positions with your CA.
Frequently asked questions
Do BPOs serving foreign clients need to file the EDF?
Yes, BPO and call-centre companies, LLPs and firms exporting services should assume the EDF applies from 1 October 2026. Those outside an SEZ file with their AD bank, and SEZ units file with the SEZ Development Commissioner.
What mode of delivery should a call centre select in the EDF?
Internet is usually appropriate for services delivered online, including internet-based voice support. If your service runs over dedicated telecom circuits, ask your bank whether it wants Internet or Others in field 1.4.
How should per-minute or usage-based invoices be shown?
Show each invoice as one row in Part 2B at the amount actually billed for that month. You can describe the usage basis, such as minutes or contacts handled, in the description or remarks columns.
How do service-level credits affect the EDF?
A service-level credit reduces what the client pays. Issue a credit note against the original invoice, reflect the reduced expected realisation in your records and net realisable value, and keep the credit note to explain the difference to the bank.
Which purpose code applies to BPO receipts?
It depends on the service. IT-enabled support, back-office processing and customer care can fall under different purpose-code groups, so confirm the code with your bank and check it on every FIRA.
Bottom line
For a BPO, a clean EDF is the by-product of clean billing: one row per invoice, consistent codes, and credit notes for every adjustment. Prepare your month's form with the free EDF form generator and keep your register up to date as payments arrive.
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.