A CA practice can run monthly EDFs for dozens of export clients on one rhythm if it does three things: keeps a master sheet of each client's fixed EDF details, sends a standard data request on the first working day of every month, and works to an internal deadline well inside the statutory one. The client still signs Part 4 and remains the exporter; your job is to make the form accurate, on time and easy for them to approve.
Key takeaways
- Separate fixed data (AD code, IEC, GSTIN, bank, signatory) from monthly data (invoices). Collect the fixed data once.
- Send every client the same data request on day one; chase on day five.
- Set an internal filing target of the 15th, leaving room before the 30-day statutory deadline.
- Classify clients by route: AD bank, STPI or SEZ Development Commissioner; and flag individuals while RBI's FAQs are pending.
- Keep an EDF register per client, including acknowledgements and realisation status.
Step 1: build a client master sheet
Most EDF errors come from fixed details typed wrongly each month. Capture them once and reuse them.
| Field | Source | Why it matters |
|---|---|---|
| Legal name and address | Incorporation documents | Field 1.11 |
| Entity type | Proprietorship, firm, LLP, company, individual | Decides whether the client is covered |
| GSTIN and PAN | Registrations | Fields 1.8 and 1.9 |
| IEC | DGFT | Field 1.7 |
| AD bank(s), branch, AD code | Bank's written confirmation | Fields 1.6 and 1.10 |
| Filing route | AD bank / STPI / SEZ DC | Where the form goes |
| Category of exporter | DTA, SEZ, EOU, Others | Field 1.5 |
| Type of export | Services or Software | Field 1.1 |
| Usual SAC codes and purpose codes | Agreed with client | Part 2B consistency |
| Authorised signatory | Bank mandate | Part 4 signature |
| Bank's EDF channel | Bank's published policy, confirmed by RM | How you submit |
| LUT status for the year | GST portal | Invoice wording check |
Review the sheet whenever a client changes banks, signatories or entity form.
Step 2: the monthly data request
On the first working day of each month, send every export client the same short request. Consistency trains clients to respond.
Subject: EDF for [Month Year] – invoices needed by [5th]
Dear [Client],
Please send us by [date]: 1. All export invoices dated [1st to last day of month], or confirmation that there were none. 2. Any credit notes issued during the month against export invoices. 3. FIRAs or bank advices for foreign payments received during the month. 4. Any change in bank account, signatory or contact details.
The EDF for [Month] is due by [statutory date]. We aim to send it to you for signature by [10th].
Regards, [Firm]
Item 3 is not needed for the EDF itself, but it keeps your realisation tracking current, which matters for the ₹10 lakh declarations and extension requests later.
Step 3: a 30-day work calendar
| Day | Task | Owner |
|---|---|---|
| 1 | Send data requests to all clients | Article assistant |
| 5 | Chase non-responders | Article assistant |
| 6–9 | Prepare EDFs; run quality checks | Senior |
| 10 | Send forms to clients for review and signature | Senior |
| 12 | Chase unsigned forms | Article assistant |
| 15 | Internal target: all EDFs submitted | Senior / client |
| 20 | Confirm bank acknowledgements; update registers | Article assistant |
| 25 | Escalate any client not yet filed | Partner |
| 30 | Statutory deadline for most months | – |
The statutory deadline is 30 days from the end of the invoice month, which lands on the 30th for most months but on 2 March 2027 for January 2027 invoices. Our EDF due dates page lists each month.
Step 4: quality checks before the client signs
- Every invoice in the client's sales register for the month appears once in Part 2B.
- Invoice numbers, dates, currencies and amounts match the GST invoices exactly.
- Field 1.22 equals the rupee total of Part 2B, at the rate method the client uses consistently.
- The AD code belongs to the branch where that month's payments land.
- SAC codes on Part 2B match the invoices.
- Part 4 alternatives are struck out correctly, and the realisation date is no later than 9 months from the latest invoice (12 months for rupee invoices).
- The signatory is on the bank's mandate.
Prepare forms quickly in our free EDF form generator, then attach the review checklist to your working papers.
Step 5: registers and realisation tracking
For each client, keep an EDF register with one line per invoice: EDF month, submission date, acknowledgement, payment date, FIRA reference, closing route (declaration or full evidence) and status. Our guide to keeping an EDF register has a template, and the glossary entry on the EDF register explains its purpose.
Every quarter, prepare the client's realisation declaration for paid invoices up to ₹10 lakh using the realisation declaration tool. Flag any invoice approaching month seven without payment so the client can request an extension in time.
A worked example
Kulkarni & Bhat, a six-partner CA firm in Pune, took on EDF work for 18 export clients in October 2026: 11 private companies, four LLPs, two proprietorships and one individual software developer.
They grouped clients by filing route and bank:
| Group | Clients | Route |
|---|---|---|
| A | 12 | AD bank, spread across five banks |
| B | 3 software exporters | Two chose their AD bank, one stayed with STPI |
| C | 2 | SEZ unit, Development Commissioner |
| D | 1 individual | On hold pending bank confirmation |
For the individual, the firm noted RBI's 7 October 2026 statement that individuals providing services abroad are not required to report, and that FAQs are awaited. It asked the client to get written guidance from his bank and kept the reply on file.
By the November cycle, 16 of 17 active clients had filed by the 15th. The one late client had changed banks without telling the firm, which is now the first question in the monthly data request.
Edge cases to plan for
- Clients with two banks. Each invoice's EDF goes to the bank where its payment lands; you may need two EDFs a month for one client.
- Credit notes after filing. The client should write to the bank with the credit note; you can draft the letter.
- Advance receipts. For services other than software, the EDF may be filed on or before the date payment is received; plan for clients who receive large advances mid-month.
- Your own firm's exports. Do not forget them. Our article on EDF for CA firms serving foreign clients covers that side.
This is general information, not legal or tax advice.
Frequently asked questions
Can a CA sign the EDF on behalf of a client?
The EDF is the exporter's declaration, and Part 4 is signed by the exporter's authorised signatory as recorded with the bank. A CA prepares and reviews the form; the client signs it.
What information should a CA collect from clients each month?
All export invoices dated in the month, credit notes, FIRAs or bank advices received, and any changes in bank, signatory or contact details. Fixed details such as AD code and IEC should be held in a master sheet.
How do I handle a client who files with STPI instead of the bank?
Software exporters outside an SEZ can file with the AD bank or STPI. Record the chosen route in the master sheet and follow STPI's process for that client, keeping non-software services with the AD bank.
Do individual clients need EDFs prepared?
RBI said on 7 October 2026 that individuals providing services abroad are not required to report, with FAQs to follow; the Regulations are not yet amended. Ask individual clients to confirm their position with their bank. Proprietorships, firms, LLPs and companies should assume they are covered.
What internal deadline should a practice set?
Many practices aim to submit by the 15th of the month after the invoice month, leaving two weeks of buffer before the statutory 30-day deadline for late data, unsigned forms or bank queries.
Bottom line
Running EDFs for many clients is a process problem, not a technical one: master data once, a standard request every month, and an internal deadline that leaves room for surprises. Build each client's form with our free EDF form generator and keep registers current from the first month.
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.