An influencer marketing agency that runs campaigns for brands based abroad files one EDF a month with its AD bank, listing every invoice raised to a foreign brand that month, within 30 days from the month's end. The form is easy. The thinking behind it isn't: how you structure the campaign invoice — one all-in campaign fee, or creator fees passed through plus an agency commission — affects your EDF rows, your purpose code and, most importantly, whether GST treats you as an exporter at all.
Key takeaways
- Each invoice to a foreign brand is one Part 2B row; one EDF covers the whole month.
- Type of export: Services. Mode of delivery: usually Internet.
- SAC 998361 (advertising services) and purpose code P1007 (advertising, trade fair, market research) are common starting points — confirm both.
- If you act as the brand's agent arranging deals with creators, GST may treat you as an intermediary, and the supply may not be an export.
- Agencies paying Indian creators on behalf of a foreign brand should keep those flows clearly documented.
Two ways agencies bill foreign brands
Most agencies use one of two models. The choice matters for the EDF and much more for GST.
| Model A: all-in campaign fee | Model B: pass-through plus commission | |
|---|---|---|
| Who contracts with creators | The agency, in its own name | The brand, with the agency arranging |
| What you invoice the brand | One campaign fee for the whole deliverable | Agency commission (and possibly creator fees "on behalf of" the brand) |
| Your role | Principal supplying an advertising service | Closer to an agent between brand and creators |
| EDF rows | One per campaign invoice | One per invoice you actually raise |
| GST risk | Lower — standard export analysis | Higher — possible intermediary treatment |
Under GST, intermediary services have their place of supply at the supplier's location — in India — which means they generally don't qualify as exports even when the client is abroad. Whether your agency is an intermediary depends on your contracts, not your invoice title. Read our explainer on intermediary services and GST and have your CA review your standard agreement before you rely on zero-rating.
What the EDF sees
The EDF doesn't decide GST, but it does reflect your invoices. If you raise an invoice to a foreign brand and the money comes from abroad, that invoice goes on the EDF. Your Part 1 entries are usually:
- 1.1 Type of export: Services.
- 1.4 Mode of delivery: Internet — strategy, briefs, content approvals and reporting happen online.
- 1.12 Mode of realisation: Others for wire or platform transfers.
- 1.21 Description: "Influencer marketing campaign services" or similar.
In Part 2B, use the description column honestly. "Campaign management fee — Diwali gifting campaign, 24 creators" tells a reviewer far more than "Marketing services".
Codes to agree once
| Code | Common starting point | Confirm with |
|---|---|---|
| SAC | 998361 — advertising services | Your CA |
| SAC for market research components | 998371 — market research | Your CA |
| Purpose code | P1007 — advertising, trade fair, market research | Your AD bank |
If a payment arrives under a generic or wrong purpose code, ask your bank to correct it early. Our purpose code finder helps you prepare for that conversation.
A worked example: October at Reelhouse Collective
Reelhouse Collective LLP, a fictional Delhi agency, runs Model A campaigns — it contracts creators itself and bills brands one fee. In October 2026 it raised:
| Invoice | Date | Brand | Country | Amount | Campaign |
|---|---|---|---|---|---|
| RC/E/26-27/018 | 04-Oct-2026 | Solano Beverages FZ-LLC | UAE | USD 22,000 | Festive launch, 30 creators, 2 platforms |
| RC/E/26-27/019 | 17-Oct-2026 | Kiri Beauty Pte Ltd | Singapore | SGD 9,500 | Always-on creator programme, October |
| RC/E/26-27/020 | 30-Oct-2026 | Solano Beverages FZ-LLC | UAE | USD 3,000 | Post-campaign performance report |
All three go on one October EDF, due 30 November 2026. With book rates of ₹84 per USD and ₹64 per SGD:
- USD 25,000 → ₹21,00,000
- SGD 9,500 → ₹6,08,000
Field 1.22 total: ₹27,08,000.
The Solano launch invoice is ₹18.48 lakh — above ₹10 lakh — so Reelhouse will close it with the FIRA and a matching instruction. The other two are under ₹10 lakh and can be closed through a periodic declaration once paid.
Reelhouse paid its 30 creators in rupees from its own account. Those are its costs, not exports, and don't appear on the EDF at all.
Pass-through creator fees: keep them visible
If you work under Model B and invoice the brand for creator fees "on behalf of" the brand, the foreign money you receive includes amounts that belong to creators. Two practical points:
- Show the split on the invoice. Separate lines for creator fees and agency commission make your EDF row, your accounting and your GST position easier to explain.
- Get advice on reimbursements. Whether pass-through amounts are part of your export value or a reimbursement is a question for your CA. Our article on reimbursement of expenses from foreign clients covers the general principle.
Brands targeting Indian audiences
Many foreign brands hire Indian agencies precisely to reach Indian consumers. The audience being in India doesn't by itself make your service domestic for FEMA purposes — your invoice is to a recipient abroad and you're paid from abroad, so it belongs on the EDF. For GST, place of supply and the intermediary question decide the outcome. Don't assume; check.
Realisation and slow payers
Brand payment cycles can be long, especially when global procurement teams are involved. Each invoice must be realised within 9 months of its date. For RC/E/26-27/018, that's 4 July 2027. Put the date in your register on day one and start chasing by month four if nothing has arrived.
This is general information, not legal or tax advice.
Frequently asked questions
Do influencer marketing agencies need to file an EDF for foreign brand campaigns?
Yes, if the agency is a business entity invoicing a brand outside India. Every invoice raised to a foreign brand in a month goes into that month's EDF, filed with the AD bank within 30 days from the end of the month.
Are payments to creators shown on the EDF?
No. The EDF lists your export invoices to foreign recipients. Payments you make to Indian creators are your costs. If you bill creator fees to the brand as a pass-through, discuss with your CA how to show them.
Is an influencer agency an intermediary under GST?
It can be, if it acts as the brand's agent arranging supplies between the brand and creators rather than supplying the campaign itself. Intermediary services generally don't qualify as exports. Your contracts decide this, so have your CA review them.
Which purpose code should the bank use for campaign fees?
P1007 (advertising, trade fair, market research) is a common fit for advertising-type campaign work, but confirm with your AD bank. Check that each FIRA carries the agreed code.
The brand's audience is in India. Is it still an export?
For the EDF, an invoice to a recipient outside India paid from abroad goes on the form. For GST, whether it's an export depends on the Section 2(6) conditions and place of supply, which your CA should confirm.
Bottom line
Structure your campaign contracts deliberately, keep creator costs separate from your export invoices and list every brand invoice on one monthly form. Build it with our free EDF form generator and raise LUT-ready invoices with the export invoice generator.
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.