A virtual assistant agency billing clients abroad has an unusual EDF profile: lots of small invoices, many clients, and payments arriving through a mix of bank wires and payment platforms. The rule is the same as for everyone, one EDF per month listing every export invoice, but the ₹10 lakh declaration route does most of the heavy lifting for VA agencies, because almost every invoice sits well under that limit.
Key takeaways
- A VA agency run as a proprietorship, firm, LLP or company should assume it must file a monthly EDF.
- Every client invoice raised in the month is a Part 2B row, even if a client gets four weekly invoices.
- Field 1.4 is Internet; field 1.1 is Services.
- Codes vary with the actual tasks. Agree a SAC and purpose code for each service line with your CA and bank.
- Invoices up to ₹10 lakh can be closed on a periodic realisation declaration, which saves a great deal of per-invoice paperwork.
Who files: the agency, not the assistants
If your agency contracts with foreign clients and invoices them, the agency is the exporter. Your assistants, whether employees or contractors in India, are not exporting anything to those clients; they are working for you.
The 7 October 2026 RBI remarks, that individuals providing services abroad are not required to report, may matter to solo VAs who contract directly with foreign clients. RBI said FAQs would follow and the Regulations have not yet been amended. Our article on whether virtual assistants need to file the EDF covers the individual's position. An agency organised as a business should not rely on those remarks.
How VA agencies bill, and what it does to the EDF
| Billing model | Example | Rows per client per month |
|---|---|---|
| Monthly per-assistant fee | USD 1,100 per full-time VA | 1 |
| Hourly, invoiced monthly | 86 hours at USD 12 | 1 |
| Hourly, invoiced weekly | Four or five invoices a month | 4 to 5 |
| Prepaid hour blocks | 40-hour block, paid in advance | 1 per block purchased |
| Setup or recruitment fee | One-off fee for onboarding a VA | 1 |
Weekly invoicing quadruples your Part 2B rows. It is not wrong, but many agencies find that a monthly invoice with a timesheet attached keeps both the books and the EDF tidier. Changing your billing cycle is a commercial decision; agree it with your clients first.
Codes: start from what the assistant actually does
"Virtual assistance" is a business model, not a service category, so there is no single code. The tasks decide it.
| Main task | SAC to discuss with your CA | Purpose code |
|---|---|---|
| Bookkeeping and accounts support | 998222 (accounting and bookkeeping) | P1005, confirm with bank |
| IT and technical support | 998313 (IT consulting and support) | Confirm with bank |
| Ad campaign or social media management | 998361 (advertising services) | P1007, confirm with bank |
| General admin, scheduling, inbox, research | Confirm the appropriate support-services code with your CA | Ask the bank which code it applies |
If one client's VA does a bit of everything, invoice under the code that matches the main service, and describe the work honestly on the invoice. Once agreed, use the same codes every month.
Payment platforms and cards
VA clients often pay by card, through a cross-border payment aggregator, or through a freelancing platform. That changes the paper trail, not the obligation.
- The EDF still goes to the AD bank where the money finally lands in your Indian account.
- The evidence of receipt may come from the platform, the aggregator's banking partner or your bank. Ask each provider what document it issues, and check its current India help pages rather than relying on old forum posts.
- Fees deducted by platforms reduce what you receive. Keep the platform's statement showing gross and net amounts for each invoice.
Our glossary note on cross-border payment aggregators explains how these routes work in general terms.
A worked example
TaskNest Remote Services LLP in Mohali places 31 assistants with small businesses in the US, UK and Australia. In January 2027 it raised 24 invoices to 21 clients, mostly monthly per-assistant fees, plus three setup fees.
| Client country | Invoices | Currency | Total |
|---|---|---|---|
| USA | 15 | USD | USD 19,850 |
| UK | 6 | GBP | GBP 6,300 |
| Australia | 3 | AUD | AUD 4,200 |
The largest single invoice is USD 2,400. TaskNest files one EDF for January 2027, due 2 March 2027, with 24 Part 2B rows. Field 1.13 and field 1.17 simply refer to Part 2B.
Because every invoice is under ₹10 lakh, TaskNest does not send its bank a FIRA and matching request for each one. Instead, at the end of each quarter, it gives the bank a single realisation declaration listing every paid invoice, its amount and date of realisation, subject to the bank accepting that format. Our article on quarterly ₹10 lakh declarations shows how to schedule this, and the free realisation declaration tool builds the document.
TaskNest's bookkeeper keeps a simple sheet: invoice number, client, amount, date paid, platform or bank, net received. That sheet feeds both the EDF and the quarterly declaration.
Late payers and small balances
Small clients sometimes pay late or drop off owing a month's fees. The full value of each invoice must be realised within 9 months of its date. Chase overdue invoices well before that, and if a balance is clearly not coming, talk to your bank and CA about how to treat it rather than leaving an EDPMS entry open indefinitely.
GST and LUT
VA services to clients abroad are zero-rated when the Section 2(6) IGST conditions are met. Agencies that provide dedicated staff working under a client's direction should have their CA check how the arrangement is classified, but in most cases the export analysis is similar. Export under LUT (Form GST RFD-11) means no IGST, and every invoice carries "Supply meant for export under LUT without payment of IGST". The free export invoice generator includes that wording. This is general information, not legal or tax advice.
Frequently asked questions
Does a VA agency need to file the EDF?
An agency operating as a proprietorship, partnership, LLP or company should assume it is covered and file a monthly EDF listing all its export invoices. RBI's 7 October 2026 remarks about individuals, pending FAQs, do not extend to businesses.
Do I need a separate EDF row for every weekly invoice?
Yes. Each invoice is one row in Part 2B. If that becomes unwieldy, consider moving clients to monthly invoicing with an attached timesheet, after agreeing it with them.
What purpose code applies to virtual assistant services?
It depends on the main task. Bookkeeping support might be P1005; advertising-related work might be P1007. For general administrative support, ask your bank which code from the RBI list it applies, and keep it consistent.
My clients pay through a payment platform. Who is my AD bank?
The bank where the money finally lands in your Indian account. Ask the platform what remittance evidence it provides, and keep its statements showing gross amounts, fees and net amounts.
Can I close many small invoices without sending a FIRA for each?
For invoices up to ₹10 lakh, the bank may close the EDPMS entries on your declaration that the money has been realised. The declaration can be periodic, such as quarterly, and is separate from the EDF.
Bottom line
VA agencies have high invoice counts and low invoice values, which makes a tidy register and the periodic declaration route your best friends. Keep one sheet, file one EDF a month, and declare quarterly. Build the monthly form in minutes with our free EDF form 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.