FEMA & RBI
SOFTEX Form Discontinued from 1 October 2026
SOFTEX stopped applying to software exports invoiced from 1 October 2026, when FEMA 23(R)/2026-RB came into force. What to do with September invoices, how the monthly EDF replaces the form, and the nine month realisation rule.
FEMA & RBI
Written by CA Nandini, Krystal7 Consultants. Last updated 1 October 2026.
The SOFTEX form is discontinued for software exports invoiced from 1 October 2026. On that date RBI notification FEMA 23(R)/2026-RB dated 13 January 2026 came into force. It brought 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. The money must reach India within nine months of the invoice date.
Invoices dated on or before 30 September 2026 still follow the old rules. Below: what changed, what to do with older invoices, how the new form works, and the realisation period that now applies.
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. Under regulation 1, they came 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:
- File SOFTEX within 30 days of each invoice date, through your STPI centre or SEZ, as before.
- Clear the late September forms now. A late September invoice has a SOFTEX due date in October. Neither the 2026 Regulations nor Circular No. 20 sets a transition rule for these forms. Ask your STPI centre and your AD bank in writing how to file each open form.
- Track realisation under the old period. Regulation 9 of the 2015 Regulations allows nine months from the date of export. FEMA 23(R)/(7)/2025-RB dated 13 November 2025 had raised this to fifteen 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.
- 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.
- Ask your AD bank first for any approval an old export needs. FEMA 23(R)/(1)/2026-RB added regulation 20 to the 2026 Regulations. It lets AD banks handle transactions made before 1 October 2026 that earlier needed RBI approval.
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 date of export (regulation 9, as amended on 5 June 2026) | Nine months from the invoice date; twelve months if invoiced or settled in rupees (regulation 5) |
| Other services | Not covered | Covered, every service export |
The first EDF for software invoices raised in October 2026 is due by 30 November 2026.
What is the realisation period for software exports from 1 October 2026?
Nine months from the invoice date. Regulation 5(1)(a) of the 2026 Regulations sets this for services, and software counts as a service. Where the export is invoiced or settled in Indian rupees, the period is twelve months from the invoice date. The AD bank may extend either period if the exporter asks and the bank accepts the reasons.
The January 2026 text of regulation 5 said fifteen months, or eighteen months in rupees. FEMA 23(R)/(1)/2026-RB dated 22 September 2026 cut these to nine and twelve months. The Gazette published the amendment on 24 September 2026, and it came into force on 1 October 2026 with the regulations. So the fifteen and eighteen month periods never applied to any export.
| Date | Instrument | Regulations amended | Realisation period for services |
|---|---|---|---|
| 13 November 2025 | FEMA 23(R)/(7)/2025-RB | 2015 Regulations, regulation 9 | Raised from nine months to fifteen months |
| 13 January 2026 | FEMA 23(R)/2026-RB, original text | 2026 Regulations, regulation 5 | Fifteen months; eighteen in rupees (never in force) |
| 5 June 2026 | FEMA 23(R)/(8)/2026-RB | 2015 Regulations, regulation 9 | Cut from fifteen months back to nine months |
| 22 September 2026 (Gazette 24 September 2026) | FEMA 23(R)/(1)/2026-RB | 2026 Regulations, regulation 5 | Nine months; twelve in rupees; in force from 1 October 2026 |
If proceeds stay unrealised for more than one year after the due date, regulation 13 applies. The exporter can then export only against full advance or an irrevocable letter of credit. Exporters already on the RBI Caution List on 30 September 2026 stay under the RBI order until they are removed from the list.
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 for its EDF format and submission route before the October invoices fall due on 30 November 2026.
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.
The parent must pay within nine months of the invoice date. If it cannot, the subsidiary asks its AD bank for an extension before the period runs out. We flag intercompany invoices older than six months, so there is time to collect.
GST runs beside this. The invoice still needs a Letter of Undertaking to be zero rated. Our guide to GST on export of services sets out that side. The setup side is in our guide to software company registration in India. The full filing process for the new form is in our EDF 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 came into force. Software exports invoiced from that date go on the Export Declaration Form (EDF), filed within 30 days from the end of the invoice month.
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. The 2026 Regulations set no transition rule for forms due in October. Ask your STPI centre and AD bank in writing how they accept them.
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?
The length stays at nine months for foreign currency invoices. Exports invoiced from 1 October 2026 get nine months from the invoice date under regulation 5 of the 2026 Regulations. Rupee invoices or settlements get twelve months. Older invoices keep the period under the 2015 Regulations, so check with your AD bank.
Did the fifteen month realisation period ever apply to software exports?
Not under the 2026 Regulations. FEMA 23(R)/(1)/2026-RB of 22 September 2026 replaced fifteen months with nine before the regulations came into force on 1 October 2026. Under the 2015 Regulations, fifteen months applied from 13 November 2025 until FEMA 23(R)/(8)/2026-RB of 5 June 2026.
Can the AD bank extend the nine month realisation period?
Yes. Under the second proviso to regulation 5 of the 2026 Regulations, the AD bank may extend the period. The exporter must ask and give reasons the bank accepts. Ask before the nine months, or twelve months for rupee exports, run out.
Who handles approvals for software exports made before 1 October 2026?
Your AD bank. Regulation 20, added by FEMA 23(R)/(1)/2026-RB, lets AD banks handle transactions made before 1 October 2026 that earlier needed RBI approval. Start with the bank that holds the SOFTEX entry in EDPMS.
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 or email [email protected] with your September invoice list.
Sources
- Reserve Bank of India, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB, 13 January 2026, amended up to 22 September 2026, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13277
- Reserve Bank of India, Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(1)/2026-RB, 22 September 2026, Gazette 24 September 2026, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13714
- Reserve Bank of India, Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(8)/2026-RB, 5 June 2026, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13467
- Reserve Bank of India, Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025, Notification No. FEMA 23(R)/(7)/2025-RB, 13 November 2025, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=12923
- Reserve Bank of India, Foreign Exchange Management (Export of Goods & Services) Regulations, 2015, Notification No. FEMA 23(R)/2015-RB, amended up to 5 June 2026, https://rbi.org.in/scripts/NotificationUser.aspx?Mode=0&Id=10256
- Reserve Bank of India, A.P. (DIR Series) Circular No. 20, Directions on Export and Import of Goods and Services, 16 January 2026, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13278&Mode=0
- Reserve Bank of India, FEMA notifications list, read 1 October 2026, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx
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WRITTEN BY
CA Nandini
Co-founder · All India Rank 49, ICAINandini Hasija is a co-founder of Krystal7. She leads brand, business development and marketing, and works with founders to define their engagement. She is a Chartered Accountant and achieved All India Rank 49 in the CA examinations.
Filed under FEMA & RBI · All insights