EDF for SEO Agencies: Export Declaration Guide

An Indian SEO agency billing overseas clients files one EDF a month listing every export invoice it raised that month, whether those are retainers, one-off audits or white-label work for a foreign agency. The form goes to the AD bank where the payments land, within 30 days from the end of the invoice month, and the trickiest decisions are not about the form at all but about which SAC and purpose codes honestly describe what an SEO retainer delivers.

Key takeaways

• Retainers, audits, content packages and performance bonuses are all export invoices. Each one is a Part 2B row.
• Field 1.4 mode of delivery is almost always Internet for SEO work.
• SEO straddles marketing and IT, so the SAC and purpose codes depend on the actual deliverable. Settle them with your CA and bank once, then apply them consistently.
• White-label work for a foreign agency is still an export, but check you are supplying on your own account and not acting as an intermediary.
• Pass-through costs such as tool subscriptions need a clear invoicing policy before they muddy your EDF values.

What an SEO agency's month looks like on paper

A typical agency's export billing falls into a few patterns:

• Monthly retainers for ongoing optimisation, content and reporting, invoiced at the start or end of each month.
• One-off technical audits or migration support, invoiced on delivery.
• Content packages sold in blocks, for example 20 articles a month.
• Performance bonuses tied to traffic or ranking targets, invoiced when the target is hit.
• White-label fulfilment for agencies in the US, UK or Australia that resell your work under their own brand.

All of these are service exports if the client is outside India and pays in foreign currency. They all go on the same monthly EDF. Our guide to EDFs for retainer agreements explains the retainer pattern in more depth.

SAC and purpose codes for SEO work

There is no single "SEO code". The right codes depend on what the invoice actually sells. The pairings below are a starting point for a conversation with your CA and bank, not a ruling.

Two practical rules help. First, describe the service on your invoice in plain words, so the code is obviously right. Second, once you settle a code for a service line, use it every month. Switching codes between months for the same retainer invites questions. Try our SAC code finder and purpose code finder to build your shortlist.

A worked example

Rankwell Digital Pvt Ltd is a 22-person SEO agency in Indore. Its current account, where all foreign payments land, is with a private-sector AD bank. In November 2026 it raised five export invoices:

Rankwell files one EDF for November, due 30 December 2026, with five Part 2B rows. Field 1.1 is Services, field 1.4 Internet, field 1.12 Others, and field 1.17 refers to Part 2B because there are four countries.

All five invoices are under ₹10 lakh each. Once paid, Rankwell can give its bank a periodic realisation declaration covering them, rather than invoice-by-invoice evidence, provided the bank accepts that format. The latest invoice is dated 30 November 2026, so the outside realisation date it writes in Part 4 is 30 August 2027.

White-label work and the intermediary question

Many Indian SEO agencies fulfil work for overseas agencies that resell it. If you produce the service yourself and invoice the foreign agency on your own account, that is generally a normal export of services.

The risk arises when your role is to arrange or facilitate a supply between a foreign party and someone else, earning a fee for connecting them. GST treats intermediary services differently, and they may not qualify as exports. If your contracts look like brokering rather than doing the work, ask your CA to review them. This is general information, not legal or tax advice.

Tool costs, ad spend and other pass-throughs

Agencies often pay for SEO tools, content platforms or occasional ad budgets on a client's behalf. How you bill these affects your EDF.

• If you build them into your fee, they simply form part of the invoice value.
• If you recharge them separately, decide whether they are part of your service or a reimbursement, and invoice consistently. Our article on reimbursements from foreign clients covers how they interact with the EDF.

Whichever route you choose, the amount on your invoice and the amount in Part 2B must match.

GST and LUT for SEO exports

Export of services is a zero-rated supply when the Section 2(6) IGST conditions are met: you are in India, the client is outside India, the place of supply is outside India, payment comes in convertible foreign exchange, and you and the client are not merely establishments of the same person.

Most agencies export under LUT, filed in Form GST RFD-11, so no IGST is charged. The invoice should carry: "Supply meant for export under LUT without payment of IGST". The EDF does not change any of this; it is a separate FEMA declaration.

A monthly routine for agencies

1. Raise all retainer invoices on a fixed date, say the 1st.
2. Raise audits and bonuses as they arise during the month.
3. On the 3rd of the next month, export the invoice list and prepare the EDF.
4. Submit through your bank's accepted channel well before the 30-day deadline.
5. Track each payment and request a FIRA; check the purpose code.
6. Each quarter, give a realisation declaration for paid invoices up to ₹10 lakh.

Frequently asked questions

Does an SEO agency need to file a separate EDF for each client?

No. One EDF per month can cover all your service exports of that month to one or more clients. Each invoice is a separate row in Part 2B with its own client, country, currency and amount.

What SAC code should an SEO agency use?

It depends on the deliverable. Campaign-led SEO and content marketing are often discussed under 998361 (advertising services), while technical audits may fit IT codes such as 998313 or 998319. Confirm with your CA and use the chosen code consistently.

Is white-label SEO for a foreign agency an export?

Generally yes, if you perform the work and invoice the foreign agency on your own account. If your role is closer to arranging services between other parties, intermediary rules may apply. Have your CA review the contract.

What if a client pays three months of retainers in one transfer?

One payment can settle several invoices. Each invoice still appears in the EDF of the month it was raised. When the money arrives, give your bank matching instructions or include the invoices in your realisation declaration if each is up to ₹10 lakh.

Do freelancers doing SEO need to file the EDF?

RBI said on 7 October 2026 that individuals providing services abroad are not required to report, with FAQs to follow; the Regulations have not yet been amended. Individual SEO freelancers should check with their bank. Agencies run as proprietorships, firms, LLPs or companies should assume they are covered.

Bottom line

For an SEO agency, the EDF is a monthly list of invoices; the real work is settling your codes and billing policies once. Get those right, then build each month's form in minutes with our free EDF form generator.