JSA Prism | Corporate and Tax | July 2026

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Export of services and software: Transition from SOFTEX to Export Declaration Form

The Reserve Bank of India (“RBI”), vide notification[1] dated January 13, 2026, has notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (“2026 Regulations”), superseding the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015 (“2015 Regulations”). The 2026 Regulations will come into force on October 1, 2026.

A significant change introduced by the 2026 Regulations is the overhaul of the export declaration framework for services and software. Under the 2015 Regulations, software exporters were required to file a separate SOFTEX form with designated Software Technology Parks of India (“STPI”) offices after obtaining a non-STPI registration. The 2026 Regulations replace this requirement with a unified Export Declaration Form (“EDF”), to be filed with Authorised Dealer (“AD”) banks for both services and software exports.

This Prism summarises the key changes and their practical implications for exporters of software and services.

Export declaration framework under 2015 Regulations

Under the 2015 Regulations, declaration of exports operated in the following manner:

• export of goods was declared through the EDF filed with customs authorities at the time of export;
• export of software was declared through the SOFTEX form, filed by units in STPI or the Domestic Tariff Area (“DTA”) with STPI authorities, or by units in Special Economic Zones (“SEZs”) with the Development Commissioner, constituting a separate compliance mechanism distinct from that applicable to goods; and
• export of other services (i.e., services other than software) was not subject to any formal declaration under the 2015 Regulations.

The SOFTEX filing obligation imposed an additional compliance burden on software exporters, requiring engagement with designated STPI offices for non-STPI registration, a process distinct from the mainstream banking channel used for goods exports.

Export declaration framework under 2026 Regulations

The 2026 Regulations introduce a unified declaration framework for all categories of exports – goods, services, and software, through a single EDF. The key changes are as follows:

• the SOFTEX form stands discontinued. All exports of services and software are now to be declared through the EDF;
• for services (other than software), the ‘specified authority’ for submission of EDF is an AD bank (for DTA units) or the Development Commissioner (for SEZ units);
• for software, the ‘specified authority’ is an AD bank or STPI (for DTA units), or the Development Commissioner (for SEZ units);
• the 2026 Regulations expressly provide that ‘services’ includes ‘software’ for the purposes of the regulations; and
• the EDF for services (including software) is required to be filed within 30 (thirty) days from the end of the month in which the invoice is raised. For exporter of services other than software, EDF can alternatively be submitted on or before the date of receipt of payment;
• a single EDF may be submitted for all exports of services to one or more recipients in a month; and
• AD banks are required to enter EDF details for service exports in the Export Data Processing and Monitoring System (“EDPMS”) within 5 (five) working days of receipt.

This represents a fundamental departure from the earlier regime where EDF was limited to goods, SOFTEX was the prescribed form for software, and other services had no formal declaration requirement. Under the 2026 Regulations, all exports – whether of goods, services, or software, are declared to the specified authority through the unified EDF.

Practical implications and key procedural requirements

• Streamlined compliance: Software exporters will no longer be required to engage with STPI offices for non-STPI registration and SOFTEX filing. The EDF can be filed directly with the AD bank, simplifying the compliance workflow and reducing regulatory touchpoints.
• Unified banking channel: With AD banks now serving as the specified authority for both services and software, exporters can manage export declarations through the same banking relationship used for the realisation of export proceeds, enabling better integration of documentation and payment monitoring.
• Consolidation of monthly invoices: A single EDF may be filed for all service exports to multiple recipients in a given month, reducing paperwork for high-volume exporters of Information Technology (“IT”) and IT-enabled services.
• EDPMS monitoring: AD banks are now required to enter EDF details in EDPMS within 5 (five) working days of receipt and are responsible for monitoring all transactions to closure. This enables more systematic tracking of outstanding export receivables for services.
• New declaration obligations for service exporters: Service providers (beyond software) who were not previously subject to a formal declaration process will now be required to file EDFs – a new compliance requirement that such exporters should incorporate into their processes.
• Filing timelines: The EDF for services (including software) should be furnished within 30 (thirty) days from the end of the month in which the invoice is raised. For services other than software, the EDF may alternatively be submitted on or before the date of receipt of payment, whichever is earlier. AD banks are empowered to extend the submission period where reasons for delay are cited.
• Realisation period: Export proceeds for services must be realised within 15 (fifteen) months from the date of invoice (18 (eighteen) months where payment is settled in Indian Rupees). AD banks may allow extensions where reasons are cited.
• Reduced value write-off: For service invoices up to INR 10,00,000 (Indian Rupees ten lakh), AD banks may permit a reduction in the realisation of export value based on a declaration from the exporter.
• Closure of EDPMS entries: For service invoices up to INR 10,00,000 (Indian Rupees ten lakh), EDPMS entries may be closed on a quarterly bulk basis based on the exporter’s declaration.
• Transition planning: With the 2026 Regulations coming into force on October 1, 2026, exporters should proactively engage with their AD banks to understand the EDF filing process, update internal export documentation workflows, and ensure team readiness before the effective date.

Conclusion

The replacement of the SOFTEX form with the unified EDF framework represents a welcome rationalisation of India’s export declaration regime for services and software. By channelling all export declarations through AD banks and a standardised form, RBI has streamlined compliances, reduced multiplicity of regulatory interfaces, and aligned the declaration process across all categories of exports.

Exporters of software and services, particularly IT companies, business process outsourcing firms, and professional services providers, should review their existing export documentation and SOFTEX filing processes, engage with their AD banks to prepare for EDF compliance, and ensure operational readiness well before October 1, 2026.

This Prism has been prepared by:

Archana Tewary Partner, Corporate

Shareen Gupta Partner, Indirect Tax

Ruchita Modi Principal Associate

For more details, please contact km@jsalaw.com.

[1] Notification No. FEMA 23(R)/2026-RB