*Written by CA Nandini, Krystal7 Consultants. Last updated 24 September 2026.*
**The SOFTEX form is discontinued with effect from 1 October 2026. On that date RBI notification FEMA 23(R)/2026-RB dated 13 January 2026 takes effect. It brings in the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, which supersede the 2015 rules that required SOFTEX. Software invoiced from 1 October 2026 goes on the Export Declaration Form (EDF): one form a month, due 30 days after the month ends.**
Invoices dated on or before 30 September 2026 still follow the old rules. Below: what changed, what to do with older invoices, and how the new form works.
## Is the SOFTEX form discontinued?
Yes, for exports invoiced from 1 October 2026. The RBI issued the new regulations on 13 January 2026, and the Gazette published them on 15 January 2026. Regulation 1 says they come into force on 1 October 2026.
From that date they supersede the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015. Those were notified as FEMA 23(R)/2015-RB dated 12 January 2016. The SOFTEX requirement sat in them and in the RBI Master Direction on Export of Goods and Services.
The 2026 Regulations do not mention SOFTEX. They define one Export Declaration Form for every kind of export, software included. The RBI also issued A.P. (DIR Series) Circular No. 20 (RBI/2025-26/194) dated 16 January 2026. That circular supersedes the Master Direction on Export of Goods and Services, and the SOFTEX circulars listed in its annex, from 1 October 2026.
## What was SOFTEX and who had to file it?
SOFTEX was the declaration for software exported in non physical form, such as code delivered online. The exporter submitted it to the designated official at STPI or the SEZ within 30 days of the invoice date. That official valued and certified the form, as the Master Direction on Export of Goods and Services required.
The rule applied to all software exporters, including those with no STPI registration. A software company with no STPI registration still filed SOFTEX through its nearest STPI centre. Services that only used IT as a tool, such as IT enabled services, needed no SOFTEX. The certified form then became the export entry that the AD bank tracked until the client paid.
## What must exporters still do for invoices dated before 1 October 2026?
Keep filing SOFTEX for them. The 2026 Regulations supersede the 2015 Regulations "except in respect of things done or omitted to be done before such supersession". An export invoiced on or before 30 September 2026 stays under the old rules.
For those invoices, work through this list:
1. File SOFTEX within 30 days of each invoice date, through your STPI centre or SEZ, as before.
2. File early. A late September invoice has a SOFTEX due date in October. Neither the RBI nor STPI has published a transition note on how they will accept those late forms. If a form is still open on 1 October 2026, ask your STPI centre and your AD bank in writing how to file it.
3. Track realisation under the old period. The 2015 Regulations allow nine months from the invoice date. FEMA 23(R)/(7)/2025-RB dated 13 November 2025 had raised this to 15 months. FEMA 23(R)/(8)/2026-RB dated 5 June 2026 brought it back to nine. Ask your AD bank which period it has recorded for each open invoice.
4. Close the old export entries. Give the bank the payment details for each SOFTEX. It then marks off the entry in EDPMS, the Export Data Processing and Monitoring System.
## What replaces SOFTEX from 1 October 2026?
The Export Declaration Form. Under regulation 3(2), a service exporter declares the full export value on an EDF. It files within 30 days from the end of the month in which it raised the invoice. The regulations count software as a service for this purpose. One EDF can cover every invoice of the month, to one client or many.
| Point | SOFTEX (invoices up to 30 September 2026) | EDF (invoices from 1 October 2026) |
|---|---|---|
| Legal basis | FEMA 23(R)/2015-RB and the Master Direction on Export of Goods and Services | FEMA 23(R)/2026-RB, regulation 3(2) |
| Where you file | STPI or the SEZ Development Commissioner | AD bank or STPI in the domestic tariff area; SEZ Development Commissioner in a SEZ |
| How often | Each invoice | One form a month for all invoices |
| Due date | 30 days from the invoice date | 30 days from the end of the invoice month |
| Realisation period | Nine months from the invoice date | 15 months from the invoice date; 18 months if invoiced or settled in rupees |
| Other services | Not covered | Covered, every service export |
The first EDF for software invoices raised in October 2026 is due by 30 November 2026.
## Do software exporters still need STPI?
Not for the export declaration. Regulation 2 names the AD bank or STPI as the "specified authority" for software in the domestic tariff area. A software exporter can file the EDF with its bank and never deal with STPI for this purpose. Units that already work with STPI can keep filing there. SEZ units file with the Development Commissioner of their SEZ.
The RBI has left the operating process to banks. Ask your AD bank now for its EDF format and submission route, so the October invoices do not wait on a bank process.
## How does the change affect a software subsidiary billing its parent?
Most development centres we set up invoice the foreign parent once a month on a cost plus basis. From October 2026 that monthly invoice goes into one EDF with the AD bank. The bank enters it in EDPMS within five working days of receipt, under regulation 18. When the parent pays, the bank matches the receipt and marks off the entry.
GST runs beside this. The invoice still needs a Letter of Undertaking to be zero rated. Our guide to [GST on export of services](/insights/gst-on-export-of-services-from-india) sets out that side. The setup side is in our guide to [software company registration in India](/insights/software-company-registration-in-india). The full filing process for the new form is in our [EDF form guide](/insights/edf-form-export-declaration-form-guide).
Frequently Asked Questions
When is SOFTEX discontinued?
From 1 October 2026, when RBI notification FEMA 23(R)/2026-RB dated 13 January 2026 takes effect. Software exports invoiced from that date go on the Export Declaration Form (EDF).
Do I still file SOFTEX for September 2026 invoices?
Yes. Invoices dated on or before 30 September 2026 stay under the 2015 Regulations. File SOFTEX within 30 days of each invoice date, and file early, because no transition note on late forms has been published.
Is the EDF just SOFTEX with a new name?
No. SOFTEX covered each software invoice and went to STPI or the SEZ. The EDF covers all service and software invoices of a month in one form, and your AD bank can receive it.
Who files the EDF for software exports?
The exporter files it with its AD bank or with STPI. SEZ units file it with the Development Commissioner of the SEZ.
What happens to SOFTEX forms I have already filed?
They stay in force for the exports they cover. The AD bank keeps tracking those entries in EDPMS until the export value is realised or the bank allows a reduction.
Does the change affect the realisation period?
Yes, for new invoices. Exports invoiced from 1 October 2026 get 15 months from the invoice date, or 18 months if invoiced or settled in rupees. Older invoices keep the period set by the 2015 Regulations.
Can Krystal7 Consultants handle the switch for us?
Yes. We file SOFTEX for open September invoices, set up the monthly EDF with your bank and reconcile the EDPMS entries each month. See our [FEMA compliance service](/services/fema-compliances.html) or email [email protected] with your September invoice list.
Facing this in your own entity?
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