EDF for Market Research Agencies: Export Declaration Guide

Market research agencies in India that run studies for foreign clients are service exporters and must declare those invoices on a monthly EDF to their AD bank from 1 October 2026. The codes are clearer than in most industries (SAC 998371 for market research and purpose code P1007 for advertising, trade fair and market research are the natural starting points), but project billing and pass-through costs need careful handling. Each invoice raised in a month becomes one row on that month's EDF, due within 30 days from the month-end.

Key takeaways

• Research agencies exporting services should file one EDF a month covering every export invoice of that month.
• SAC 998371 and purpose code P1007 are the usual starting points; confirm both with your CA and bank.
• Milestone invoices (kick-off, fieldwork, report) each appear in the month they are raised.
• Respondent incentives and other pass-through costs billed to the client need a consistent treatment on invoices and the EDF.
• Large project invoices often exceed ₹10 lakh, so expect to provide payment evidence and matching instructions to close EDPMS entries.

How research projects are billed

Research work rarely fits a neat monthly retainer. A typical international study moves through stages, and so does the billing.

The 9-month realisation clock runs from each invoice date, so a project billed in three stages has three separate clocks.

Pass-through costs: what goes on the EDF

Agencies often bill respondent incentives, recruitment fees or venue hire at cost. How these are treated for GST depends on whether you act as a pure agent, and that is a CA question. For the EDF, the rule of thumb is that it follows your invoices to the foreign client.

• If incentives are billed on the same export invoice as your fee, the invoice total goes into Part 2B.
• If you bill them on a separate invoice to the foreign client, that invoice is a separate row.
• Whatever you choose, keep it consistent across projects so your register and FIRAs reconcile.

Our article on reimbursement of expenses from foreign clients covers the question in more depth.

Codes for research agencies

SAC 998371 covers market research services and is the natural fit for survey design, fieldwork and analysis. If you also do management consulting on the back of research, 998311 (management consulting) may apply to that part. Agree the mapping with your CA. Our SAC code finder lists the common options.

Purpose code P1007 covers advertising, trade fair and market research. Ask your client's bank-facing team to reference the service correctly in payment instructions, and check the code on each FIRA from your bank. If an inward remittance arrives under the wrong code, correct it early.

A worked example

Lighthouse Insights Pvt Ltd in Chennai is running a consumer study across three Indian cities for a Japanese electronics brand, plus an ongoing online tracker for a US beverage company.

The October EDF, due 30 November 2026, has two rows. The November EDF, due 30 December 2026, has three rows, including the separate incentives invoice. The final 30% report milestone for Japan will go on whichever month's EDF covers the date it is invoiced.

At an assumed rate of ₹84.00, the Japanese kick-off invoice is ₹11,34,000, above ₹10 lakh, so Lighthouse provides the FIRA and matching instructions to close it. The tracker invoices at about ₹3,52,800 each can be closed through a periodic declaration of realisation; our realisation declaration tool prepares it.

Note that the research is about the Indian market, conducted in India. That alone does not make the place of supply India: for most services, place of supply follows the location of the recipient, here Japan and the US. Still, confirm with your CA if any part of a project involves services on goods or people located in India.

GST and the EDF

Export of services is zero-rated when the Section 2(6) IGST Act conditions are met. Most research agencies export under LUT, filed on Form GST RFD-11, and print "Supply meant for export under LUT without payment of IGST" on export invoices. If you instead pay IGST and claim a refund, payment evidence from FIRAs becomes even more important.

The EDF is a FEMA declaration. It does not change your GST or income-tax position; it simply records each export for your bank and RBI.

This article is general information, not legal or tax advice.

A monthly checklist for research agencies

1. Pull all export invoices dated in the month, including incentive and pass-through invoices.
2. Confirm each row's currency and amount match the invoice exactly.
3. Use SAC 998371 for research rows unless your CA has mapped otherwise.
4. Total in INR using one documented rate approach.
5. Sign Part 4 and submit to your AD bank before the due date. Our EDF due date table lists every month.
6. As payments arrive, match FIRAs to invoices and update your register.

Frequently asked questions

Which SAC code do market research agencies use on export invoices?

SAC 998371 covers market research services and is the usual starting point for survey and research work. If part of the engagement is consulting rather than research, a different code such as 998311 may apply to that part, so confirm the mapping with your CA.

What purpose code applies to market research receipts?

Purpose code P1007 covers advertising, trade fair and market research services. Confirm the code with your bank and check it on each FIRA, because a wrong code can complicate matching and export documentation later.

Do respondent incentives billed to a foreign client go on the EDF?

The EDF follows your invoices to the foreign client. If incentives are on the export invoice, the invoice total is declared; if billed separately to the client, that invoice is its own row. The GST treatment of such costs is a separate question for your CA.

Does research conducted in India for a foreign client count as an export?

For most services, place of supply is the location of the recipient, so research for a client located abroad is generally an export if all GST conditions are met. Special rules can apply where services are performed on goods or people in India, so check unusual projects.

How do milestone invoices affect the EDF due date?

Each milestone invoice is declared on the EDF for the month in which it is raised, due within 30 days from that month's end. Each invoice also has its own 9-month realisation window from its invoice date.

Bottom line

Research agencies have the advantage of clear codes; the work lies in tracking staged invoices and pass-through costs. Build each month's declaration with our free EDF form generator and keep every milestone tied to its FIRA.