RBI and FEMA

Do freelancers still need to file SOFTEX in India?

Author:: Editorial team, serviceexportguide.com
Verified by:: Editorial team
Published: 28 October 2026
Last modified: 30 October 2026
Reading time: 7 min read

Short answer

SOFTEX was the declaration for software exports under regulation 6(B) of the FEMA (Export of Goods & Services) Regulations, 2015.² RBI Circular No. 20 superseded the SOFTEX circulars from 1 October 2026.³ From that date, every freelancer who exports services files an Export Declaration Form (EDF).¹ The EDF is due within 30 days from the end of the invoice month.¹

Applies to	Governed by	Deadline	Penalty	Last verified
Every freelancer who exports services, from 1 October 2026¹	FEMA (Export and Import of Goods and Services) Regulations, 2026, regulation 3(2)¹	EDF within 30 days from the end of the invoice month; non-software services may file on or before the payment date¹	Not set out in the regulations cited on this page	2026-10-30
Freelancers exporting software, until 30 September 2026²	FEMA (Export of Goods & Services) Regulations, 2015, regulation 6(B)²	Not applicable: SOFTEX circulars superseded from 1 October 2026³	Not applicable	2026-10-30

SOFTEX was the form Indian software exporters used to declare exports sent abroad electronically. The definition of software behind it was broad enough to reach some design, video and writing work as well as code.² From 1 October 2026 the SOFTEX circulars are superseded, and every freelancer who exports services files an Export Declaration Form (EDF) instead.¹³

What was SOFTEX, and did freelancers have to file SOFTEX before October 2026?

SOFTEX was the declaration form for software exports, and freelancers had to file SOFTEX only if their work was an export of software within the 2015 rules. Regulation 6(B) of the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015 required the SOFTEX form for "export of computer software and audio/video/ television software", submitted to the designated official at Software Technology Parks of India (STPI), a Free Trade Zone or a Special Economic Zone (SEZ).²

Software freelancers: filed SOFTEX through STPI or the SEZ designated official.²
Other service freelancers: regulation 3(3) of the 2015 Regulations said an exporter of services to which no form applied could export "without furnishing any declaration", while still having to realise and repatriate the money.²

So a consultant, tutor or marketer whose work was not software filed no declaration under the 2015 rules.²

Why did the SOFTEX software definition worry designers and video editors?

The software definition worried designers and editors because it covered far more than code. Both the 2015 and 2026 Regulations define software as "any computer programme, database, drawing, design, audio/video signals, any information by whatever name called in or on any medium other than in or on any physical medium".¹² For example, a logo sent as a file, an edited YouTube video, or a dataset could fall within those words.

Under SOFTEX, that classification decided whether a freelancer filed at all. Under the EDF, every service exporter files, and the classification affects only the deadline option and who can certify the form.¹

Which freelancers does the EDF apply to from 1 October 2026?

The EDF applies to every freelancer who exports services from 1 October 2026, under regulation 3(2) of the FEMA (Export and Import of Goods and Services) Regulations, 2026 (the 2026 Regulations).¹ The explanation to regulation 2 says "services" includes software, so a single rule covers developers and non-developers alike.¹

Freelancer	Under SOFTEX (until 30 September 2026)	Under the EDF (from 1 October 2026)	Best for
Developer billing a US startup	SOFTEX via STPI or SEZ designated official	EDF to the bank or STPI within 30 days of month end	Monthly filing after the invoice month
UI designer billing a German agency	SOFTEX if the work counted as software; otherwise no declaration	EDF; if treated as non-software, may file by payment date	Confirming the classification with the bank first
Video editor billing a Canadian creator	SOFTEX if the work counted as software; otherwise no declaration	EDF, same as above	Confirming the classification with the bank first
Business consultant billing a UK firm	No declaration (regulation 3(3))	EDF; may file on or before payment date	Filing when the payment arrives
Online tutor teaching students in the UAE	No declaration (regulation 3(3))	EDF; may file on or before payment date	Filing when the payment arrives

The table summarises the 2015 and 2026 Regulations.¹² Confirm with your bank how it classifies your work, since the Regulations do not classify professions.

How does a freelancer file the EDF in practice?

A freelancer can usually file one EDF a month with the bank that receives export payments.¹

Find out your bank's process: banks set their own channel; each must publish the main features of its export SOP on its website.¹
Bundle the month's invoices: regulation 3(2)(a) allows one EDF for all services exported to one or more clients in a month.¹
Pick your deadline: within 30 days from the end of the invoice month; or, for services other than software, on or before the date payment is received.¹
Fill the form: list each invoice with the client, country, invoice number, date, currency, amount and SAC code. See EDF form fields.
Close the loop: for invoices up to ₹10 lakh, the bank may close the EDPMS entry on your declaration, which you can give quarterly.¹

The steps above follow the 2026 Regulations; the exact upload channel depends on the bank.¹

How does the EDF work when a freelancer is paid through a payment aggregator?

Freelancers paid through a cross-border payment aggregator (PA-CB) still own the EDF obligation, because regulation 3(2) applies to the exporter.¹ RBI's Master Direction on Regulation of Payment Aggregator says a PA-CB "shall provide the documents / information required by the exporter" to the exporter's AD bank for closure of the EDPMS entry.⁵ How each platform routes this varies, so ask it which bank holds your entries and what it needs from you.

If a marketplace or a client's parent company pays you instead of the client, record that party in the EDF's third-party fields and keep the agreement on file.¹

What documents and deadlines apply to a freelancer's EDF?

A freelancer's EDF needs the month's export invoices and must be filed within 30 days from the end of the invoice month, with payment due within nine months of the invoice.¹⁴

Item	Rule	Best for
EDF filing date	Within 30 days from the end of the invoice month¹	All freelancers, including software
Alternative filing date	On or before the date payment is received, for services other than software¹	Consultants, tutors, marketers
Realisation period	Nine months from the invoice date; twelve months if invoiced or settled in rupees¹⁴	Every export invoice
EDPMS closure on declaration	Invoices up to ₹10 lakh, declaration can be given quarterly¹	Freelancers with many small invoices
Third-party payer details	Recorded in the EDF's third-party fields, with the agreement on file¹	Freelancers paid by a marketplace or parent company

Keep each invoice and bank advice with the matching EDF.

What happens if a freelancer's payment arrives late or short?

A freelancer whose payment arrives late can ask the bank to extend the realisation period, and one whose payment arrives short can ask the bank to reduce the export value.¹ Payment for each invoice must reach India within nine months from the invoice date, or twelve months if invoiced or settled in rupees.¹⁴

Short payment: say a client pays less after a dispute over scope; the bank may allow a reduction in export value, and for invoices up to ₹10 lakh it may do so on your declaration.¹
Late payment: the bank can extend the realisation period under regulation 5.¹

See the export realisation period guide and FEMA rules for freelancers.

Which RBI rules replaced SOFTEX for freelancers?

The FEMA (Export and Import of Goods and Services) Regulations, 2026 replaced SOFTEX for freelancers, and RBI Circular No. 20 superseded the SOFTEX circulars from 1 October 2026.¹³

Rule	Clause	Date	Plain meaning
FEMA (Export of Goods & Services) Regulations, 2015²	Regulation 6(B)	Applied until 30 September 2026	SOFTEX for software exports
FEMA (Export of Goods & Services) Regulations, 2015²	Regulation 3(3)	Applied until 30 September 2026	No declaration for services without a form
FEMA (Export and Import of Goods and Services) Regulations, 2026, FEMA 23(R)/2026-RB¹	Regulation 3(2) and explanation to regulation 2	Dated 13 January 2026, in force 1 October 2026	EDF for every service exporter, software included
RBI A.P. (DIR Series) Circular No. 20³	Annex: circulars superseded	16 January 2026	SOFTEX circulars superseded from 1 October 2026
FEMA 23(R)/(1)/2026-RB⁴	Regulation 5 as amended	22 September 2026	Nine-month realisation period
Master Direction on Regulation of Payment Aggregator⁵	PA-CB duties	15 September 2025	PA-CB gives documents to the AD bank for EDPMS closure

Read the regulation text itself when a bank's checklist seems to differ.¹³

What are the common mistakes freelancers make after SOFTEX ended?

The most common mistake is assuming that a freelancer who never filed SOFTEX still has nothing to file, when the 2026 Regulations require an EDF from every exporter of services.¹

Assuming non-software work is exempt: consultants and tutors who filed nothing under regulation 3(3) of the 2015 rules now file the EDF.¹²
Assuming the platform files: the EDF duty sits with the exporter even when a PA-CB passes documents to the bank.¹⁵
Missing the month-end deadline: software exports do not get the payment-date option.¹
Forgetting old SOFTEX entries: the RBI circulars on SOFTEX procedure were superseded from 1 October 2026, and the 2026 Regulations do not set out how pending SOFTEX entries close.¹³ Keep your old SOFTEX forms, invoices and bank advices, and ask your bank about any older entry it still shows as open.

Each freelancer's position depends on the work and the bank's process, so check with your bank or a chartered accountant if you are unsure.

How did we verify this?

We checked this page against the sources below on 30 October 2026. Read our methodology or report an error.

Frequently asked questions

I am a freelance developer. Do I file SOFTEX or the EDF in 2026?+

A freelance developer files the EDF. For invoices from 1 October 2026, software exports are declared on the Export Declaration Form to your Authorised Dealer bank or STPI, within 30 days from the end of the invoice month.¹ The SOFTEX circulars were superseded from that date, so no new SOFTEX form is filed.³

I never filed SOFTEX. Do I need to file an EDF now as a freelancer?+

Yes, if you export services. Under the 2015 Regulations, services not covered by a form needed no declaration.² The 2026 Regulations require an EDF from every exporter of services from 1 October 2026, so consultants, tutors and marketers who never filed SOFTEX now file the EDF with their bank.¹

Do I need STPI registration as a freelancer to file the EDF?+

A freelancer does not need STPI registration to file an EDF. For software exported from the Domestic Tariff Area, an Authorised Dealer bank is a specified authority, and for other services the specified authority is the bank.¹ Most freelancers therefore file the EDF with the bank that receives their export payments.

I am paid through a payment platform. Who handles the EDF for a freelancer?+

The 2026 Regulations put the EDF duty on the exporter, so the freelancer remains responsible.¹ RBI's payment aggregator directions require a PA-CB to give your bank the documents needed to close the EDPMS entry.⁵ Ask the platform which bank holds your entries and what it needs from you each month.

Is there an EDF exemption for freelancers earning small amounts?+

There is no value threshold for the EDF under the 2026 Regulations, so small invoices are covered too.¹ Invoices up to ₹10 lakh can be closed in EDPMS on the freelancer's own declaration, which can be given quarterly.¹ This reduces paperwork for small invoices without removing the filing duty.

How long does a freelancer have to receive payment from a foreign client?+

A freelancer must receive payment for each export invoice within nine months from the invoice date under the 2026 Regulations as amended.¹⁴ The period is twelve months if the invoice is raised or settled in Indian rupees.⁴ The bank can extend the realisation period under regulation 5.¹

This page is general information for Indian service exporters, not tax or legal advice. Rules change and outcomes depend on your facts, so confirm with a chartered accountant before acting.

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