RBI and FEMA

How did the EDF replace SOFTEX, and what happens to older SOFTEX forms?

Author:: Editorial team, serviceexportguide.com
Verified by:: Editorial team
Published: 28 October 2026
Last modified: 30 October 2026
Reading time: 6 min read

Short answer

The Export Declaration Form (EDF) replaced SOFTEX on 1 October 2026.¹ The FEMA (Export and Import of Goods and Services) Regulations, 2026 superseded the 2015 export regulations.¹ A.P. (DIR Series) Circular No. 20 superseded the SOFTEX circulars.³ Regulation 20 tells banks to handle pre-October 2026 transactions that earlier needed RBI approval.² The rules say nothing specific about pending SOFTEX forms.¹

Applies to	Governed by	Deadline	Penalty	Last verified
Software exporters, invoices from 1 October 2026¹	FEMA (Export and Import of Goods and Services) Regulations, 2026; Circular No. 20 dated 16 January 2026¹³	EDF within 30 days from the end of the invoice month¹	Not set out in the regulations cited on this page	2026-10-30
SOFTEX forms and transactions before 1 October 2026¹²	Regulation 20, inserted by FEMA 23(R)/(1)/2026-RB dated 22 September 2026²	Not set out in the texts; ask your bank¹	Not applicable	2026-10-30

For software exporters, 1 October 2026 was a switch date: the SOFTEX form stopped and the Export Declaration Form (EDF) started.¹ This page sets out how the switch happened legally, what replaced what, and what the official texts say about SOFTEX forms and invoices from before that date, including where they are silent.

For the old filing steps see SOFTEX form filing. For how to file the EDF see the EDF guide for service exporters.

What is the SOFTEX to EDF transition?

The SOFTEX to EDF transition is the switch on 1 October 2026 from the SOFTEX form under the 2015 export regulations to the Export Declaration Form under the 2026 Regulations.¹⁵

Old form: the FEMA (Export of Goods & Services) Regulations, 2015 were the source of Form SOFTEX.⁵
New form: the 2026 Regulations provide the EDF, which covers all services, including software.¹
Switch date: the Regulations, the 22 September 2026 amendment and the directions to banks all came into force on 1 October 2026.¹²³

The legal detail of which instruments did this is set out further down this page.

Who does the SOFTEX to EDF change apply to?

The SOFTEX to EDF change applies to every software exporter, and through the EDF it now reaches every exporter of services as well.¹⁵

Exporter	Before 1 October 2026	From 1 October 2026	Best for
Software exporter in the Domestic Tariff Area	SOFTEX to the designated official at STPI⁵	EDF to an Authorised Dealer (AD) bank or STPI¹	Filing with the bank that receives payments
SEZ unit exporting software	SOFTEX to the SEZ designated official⁵	EDF to the SEZ Development Commissioner¹	Filing through the SEZ office
Exporter of other services	No SOFTEX, which covered software only⁵	EDF, which covers all services¹	Service exporters new to declarations
Exporter with pending SOFTEX entries	Handled under the 2015 Regulations⁵	Handled by the bank under regulation 20²	Exporters closing out older records

Ask your bank which row fits your business if you are unsure.

How do software exporters move from SOFTEX to the EDF?

A software exporter moves from SOFTEX to the EDF by closing out old SOFTEX entries with the bank and filing an EDF for every month from October 2026.¹

List open SOFTEX entries: ask your bank for your outstanding export entries in the Export Data Processing and Monitoring System (EDPMS). See how to check EDPMS outstanding.
Keep certified copies: the Master Direction asked banks to hold duplicate SOFTEX copies until full realisation.⁶ Keep your own set with invoices and bank advices.
Ask about pending forms: for September 2026 invoices without a certified SOFTEX, ask the bank or STPI what it wants, since the 2026 Regulations are silent on this.¹
File EDFs for October 2026 onwards: file within 30 days from the end of each invoice month.¹
Track realisation: count nine months from each invoice date for invoices from 1 October 2026 (twelve if invoiced or settled in rupees).¹ See the export realisation period guide.

These steps keep the old and new records separate, which makes questions from the bank easier to answer.

What changes between SOFTEX and the EDF?

The EDF moves software declarations from a valuation step at STPI or an SEZ to a declaration that can be made directly to the bank.¹⁵

Point	SOFTEX	EDF	Best for
Who receives it	Designated official at STPI, an FTZ or SEZ⁵	AD bank or STPI in the Domestic Tariff Area, or the SEZ Development Commissioner¹	Exporters who bank with one AD bank
Valuation	Invoices "subject to valuation of export declared on SOFTEX form" by the designated official⁶	Certificate states that the declared value is as per the invoices submitted¹	Exporters whose invoice value is final
Deadline	Not later than 30 days from the date of invoice or of the last invoice in a month⁶	Within 30 days from the end of the month in which the invoice was raised¹	Month-end batch filing
Scope	Software only⁵	All services, including software¹	Mixed software and service businesses

Check each invoice date against the switch date before choosing which column applies.

What happens to SOFTEX forms filed before 1 October 2026?

SOFTEX forms filed before 1 October 2026 were not cancelled by the change. The 2026 Regulations supersede the 2015 Regulations "except in respect of things done or omitted to be done before such supersession".¹ That wording preserves the legal effect of declarations already made, and of any failure to comply before that date.

What the texts add is regulation 20, inserted by the 22 September 2026 amendment: banks "shall handle transactions related to the export and import of goods and services ... undertaken prior to October 01, 2026, which hitherto required approval of the Reserve Bank of India" under the 2015 Regulations and the Master Direction "as updated till July 17, 2026".²

For example: a request that once needed RBI's Regional Office, such as an extension or write-off beyond the bank's old powers on a pre-October SOFTEX export, now goes to your bank.²⁶
Uncertified forms: the texts do not say whether a SOFTEX form not yet certified on 30 September 2026 should be completed, or replaced by an EDF.¹
Older invoices: the texts do not say whether invoices raised before 1 October 2026 need an EDF.¹
Realisation: the texts do not say which realisation period applies to a pre-October invoice still unpaid.¹

Ask your bank about each of these and keep its answer in writing.¹

Which RBI rules replaced SOFTEX with the EDF?

Two RBI instruments together replaced SOFTEX on 1 October 2026: the 2026 Regulations and A.P. (DIR Series) Circular No. 20.¹³

Instrument	Clause	Date	Plain meaning
Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB¹	Preamble	13 January 2026	Made "in supersession of the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015"
A.P. (DIR Series) Circular No. 20³	Paragraph 4 and Annex	16 January 2026	The Master Directions on Export and on Import of Goods and Services, and the circulars in its Annex, "shall stand superseded"
FEMA 23(R)/(1)/2026-RB²	Regulation 20 inserted	22 September 2026	Banks handle pre-October 2026 transactions that earlier needed RBI approval

The SOFTEX circulars in the Annex to Circular No. 20 include Circular No. 9 of 25 October 2001 ("Certification of SOFTEX Forms"), Circular No. 80 of 15 February 2012 and Circular No. 47 of 23 October 2012 (simplification and revision of the SOFTEX procedure), Circular No. 66 of 1 January 2013 (SOFTEX procedure at SEZs) and Circular No. 27 of 5 November 2015 (bulk SOFTEX).³

What was the timeline of the SOFTEX to EDF change?

The SOFTEX to EDF change was announced nearly nine months before it took effect.¹²⁴

Date	Event
2 July 2024 and 4 April 2025	RBI press releases publishing draft regulations and draft directions for comment
13 January 2026	2026 Regulations notified (published in the Gazette on 15 January 2026)
16 January 2026	Circular No. 20 issued; RBI press release announces both
22 September 2026	Amendment notified (published 24 September 2026): realisation period set at nine months, regulation 20 inserted
1 October 2026	Regulations, amendment and directions in force; SOFTEX ends

The dates come from the Regulations, the amendment and RBI's press release.¹²⁴

What are the common mistakes in the SOFTEX to EDF transition?

The most common mistake is assuming the official texts settle every pre-October case, when they are silent on pending SOFTEX forms, older invoices and their realisation period.¹

Treating old forms as void: the supersession does not affect things done before it.¹
Going to RBI for old approvals: regulation 20 sends these to the bank.²
Using the SOFTEX deadline: the EDF runs 30 days from the end of the invoice month, while SOFTEX ran from the invoice date.¹⁶
Discarding certified copies: banks held duplicate SOFTEX copies until full realisation, so keep yours too.⁶

Because the transition rules leave gaps, confirm your specific position with your bank or a chartered accountant.

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

When did SOFTEX end for Indian software exporters?+

SOFTEX ended on 1 October 2026, when the FEMA (Export and Import of Goods and Services) Regulations, 2026 and RBI Circular No. 20 both came into force.¹³ From that date the 2015 Regulations and the SOFTEX circulars stood superseded, and software exports are declared on the Export Declaration Form instead.

Is my old SOFTEX form still valid after 1 October 2026?+

A certified SOFTEX form remains a record of a past declaration, because the supersession of the 2015 Regulations does not affect things done before it.¹ How the bank closes the related entry is for your bank to decide under regulation 20, inserted by the 22 September 2026 amendment.² Keep the form with its invoices.

I invoiced in September 2026 but had not filed SOFTEX by 1 October. What now?+

The 2026 Regulations do not address a September 2026 invoice with no SOFTEX filed by 1 October 2026.¹ Ask your bank or STPI before filing anything, and keep the invoice and all correspondence. Get the bank's answer in writing so that you can show which route you followed if the entry is queried later.

Do I file an EDF for invoices raised before 1 October 2026?+

The 2026 Regulations do not say expressly whether invoices raised before 1 October 2026 need an Export Declaration Form.¹ Ask your bank how it is treating those invoices and keep its answer on file. Invoices raised from 1 October 2026 onwards do need an EDF within 30 days from the end of the invoice month.¹

Which realisation period applies to a pre-October SOFTEX invoice?+

The 2026 Regulations do not set a transition rule for the realisation period of a pre-October SOFTEX invoice that is still unpaid.¹ Ask your bank. For invoices from 1 October 2026, the period is nine months from the invoice date, or twelve months if invoiced or settled in rupees.¹ The export realisation period guide explains the history.

Does the EDF still need valuation by STPI like SOFTEX did?+

The Export Declaration Form does not need the valuation step that SOFTEX had. Under the old Master Direction, SOFTEX invoices were subject to valuation by the designated official.⁶ The EDF certificate states that the declared value is as per the invoices submitted, and software exporters in the Domestic Tariff Area can file it with their bank.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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