EDF from 1 October 2026: SOFTEX Is Gone — What Service & Software Exporters Must Do

Effective: 1 October 2026
Law: FEMA (Export & Import) Regulations, 2026
Big change: SOFTEX replaced by EDF for services
Money home in: 9 months (12 if in INR)

The short version

From 1 October 2026, service exporters must file an Export Declaration Form (EDF) with their bank — within 30 days from the end of the month the invoice is raised.
SOFTEX is gone. Software exporters move to the EDF, and service exporters who had no form before — freelancers, agencies, consultants — must now file too.
Export proceeds must come home in 9 months (12 months if invoiced/settled in INR) — cut from 15/18 months by an RBI amendment of 22 September 2026.
The real work is reconciliation: your EDF, your GST returns (GSTR-1 Table 6A, GSTR-3B) and your bank's EDPMS entries all have to agree — or your zero-rating and refunds come under question.

If you export services — software, consulting, design, freelance work — a quiet but significant compliance change took effect on 1 October 2026. The old SOFTEX route is finished, and a single declaration regime now pulls export reporting, foreign-exchange realisation and your GST filings into one chain that has to reconcile. Miss a link, and the trouble shows up where it hurts: your refunds.

What exactly changed

Under the FEMA (Export and Import of Goods and Services) Regulations, 2026 (notified in January 2026, amended 22 September 2026, effective 1 October 2026), the reporting of service exports moves to the Export Declaration Form (EDF). Software — previously declared through SOFTEX — is now treated as a service and reported through the EDF as well.

One clarification worth getting right

This is often described as "one EDF now covers goods, services and software." Not quite. Goods continue under the usual shipping-bill process. The EDF regime here is for services — with software folded in as a service. So the practical shift is: SOFTEX out, EDF in, for software and all other service exports.

Who has to file now

The widening of scope is the headline. It's not just software companies:

Software exporters — transitioning off SOFTEX onto the EDF.
Service exporters of every kind — consulting, professional services, design, marketing, support.
Freelancers and small agencies who had no export form at all before — the gig and independent-IT economy is now formally inside the FEMA reporting net.

The mechanics: when, where, how long

Question	Answer
When to file	Within 30 days from the end of the month the invoice is raised. October invoices → due by 30 November 2026.
How often	One consolidated EDF per month is allowed, covering all your service recipients for that month.
Where — services	Your AD bank (Authorised Dealer).
Where — software (DTA)	Your AD bank or STPI (Software Technology Parks of India).
Where — SEZ units	SEZ Development Commissioner.
Realisation period	9 months from invoice date; 12 months if invoiced or settled in INR.

The 9-month clock is the part to watch

The January 2026 regulations had set a 15-month realisation window (18 months for INR). The 22 September 2026 amendment cut it to 9 months (12 for INR) before the regime even went live. That's a materially tighter leash on when your foreign payment must actually land — plan collections, not just invoices, around it.

The ₹10 lakh rule — simpler, not optional

There's a common misread here. For invoices up to ₹10 lakh, the bank can close the EDPMS entry on your own declaration that payment has been received — with lighter paperwork, and quarterly bulk closure allowed. But this is a simplified closure mechanism, not an exemption from filing. You still file the EDF and you still report; only the closure step is eased.

Where GST meets FEMA — the reconciliation nobody flags

This is the part the headline summaries skip, and it's where most of the real risk sits. Your export of services touches three systems that now have to tell the same story:

GST — GSTR-1 Table 6A: your export invoices, reported here for zero-rated supplies.
GST — GSTR-3B: the same exports shown as zero-rated outward supplies.
FEMA — EDF & EDPMS: the same invoices declared to your bank and tracked to realisation.

When these three don't line up — a different invoice value, a missing entry, a timing gap — it undermines the very things an exporter depends on: the zero-rating of your supplies, your LUT-based ITC refund via RFD-01, and clean foreign-exchange compliance. Mismatches are exactly what trigger refund queries and delays. Treating EDF, EDPMS and your GST returns as one reconciled set — rather than three separate chores — is what keeps refunds moving and notices away.

Keep your FIRA / FIRC — every payment, matched to an invoice

Whether you collect through your bank directly or via platforms like Wise, Skydo or Stripe, you still file the EDF. Retain the FIRA / FIRC or payment advice for each inward remittance and match every payment to the specific invoice it settles. That paper trail is what lets your bank close the EDPMS entry and what substantiates your GST refund.

What to do now — a monthly rhythm

Ask your AD bank for its EDF process — form, portal, cut-off and documentation — so you're set before your first monthly deadline.
Keep a monthly invoice register of all export-of-service invoices, client by client.
File one consolidated EDF a month, within 30 days of month-end.
Match every inward payment to its invoice, and file away the FIRA/FIRC or payment advice.
Reconcile the trio each month — GSTR-1 6A, GSTR-3B zero-rated, and EDPMS — as part of your monthly closing, not at refund time.
Track the 9-month clock per invoice so nothing slips past the realisation window.

Export services or software? Get your EDF rhythm right.

efiletax can set up your monthly EDF filing, reconcile it with your GSTR-1, GSTR-3B and EDPMS, and keep your LUT refunds flowing — so the new regime is routine, not risk.

Talk to our export-compliance team

Disclaimer: This article explains the FEMA (Export and Import of Goods and Services) Regulations, 2026 (effective 1 October 2026, as amended 22 September 2026) and its interaction with GST, for general understanding, and is current as at the date of publication. Procedures, timelines and bank requirements are governed by the Regulations, RBI circulars and your AD bank's process — verify the current position before filing. This is not legal, tax or foreign-exchange advice; please consult a qualified professional. Talk to efiletax if you need help.