Export of Services under FEMA: New EDF Framework from 1 October 2026

Software exporters transition from SOFTEX to EDF, while other service exporters come within the export declaration framework

The FEMA compliance framework governing export of services from India undergoes an important change from 1 October 2026.

The Reserve Bank of India, through the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, has introduced a revised Export Declaration Form (EDF) framework covering services, including software. The Regulations were notified on 13 January 2026 and come into force from 1 October 2026, superseding the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015. RBI Notification EDF_13.01.26

The impact differs depending upon the nature of services exported:

• Software exporters transition from the existing SOFTEX declaration framework to EDF.
• Other service exporters, for whom an export declaration was generally not required where no prescribed form applied, will now come within the EDF framework.

Existing Position — Up to 30 September 2026

Software Exports — SOFTEX

Under the 2015 Regulations, export of computer software and audio/video/television software is subject to the SOFTEX declaration mechanism.

Clause 6B requires Form SOFTEX to be submitted to the designated official at STPI, FTZ or SEZ. After certification, the original is forwarded to RBI, the duplicate is returned to the exporter and the triplicate is retained by the designated official. RBI Notification EDF_05.06.26(1)

Clause 6C further provides that, upon realisation of export proceeds, duplicate copies of export declaration forms, including EDF and SOFTEX, are retained by the Authorised Dealer. RBI Notification EDF_05.06.26(1)

Clause 10 requires export documents to be submitted to the AD Bank mentioned in the relevant export declaration form within 21 days from the date of export or certification of the SOFTEX form, subject to the permitted relaxation for delayed submission. RBI Notification EDF_05.06.26(1)

Accordingly, software exports already operate within a prescribed declaration and documentation framework.

Other Service Exports

The position is different for services to which none of the prescribed declaration forms applies.

Under the existing Regulations, such services may be exported without furnishing an export declaration, although the exporter continues to be responsible for realisation and repatriation of the foreign exchange due on the export. RBI Notification EDF_05.06.26

What Changes from 1 October 2026?

The 2026 Regulations expressly provide that “services” includes “software.” Regulation 3(2) requires an exporter of services to furnish an EDF specifying the amount representing the full export value of the services. RBI Notification EDF_13.01.26 RBI Notification EDF_13.01.26

The transition can broadly be summarised as follows:

The change is therefore more than the replacement of one form with another.

For software exporters, it represents a transition from an existing SOFTEX-based compliance mechanism. For many other service exporters, it introduces a new recurring FEMA declaration requirement.

When is EDF to be Furnished?

As a general rule, Regulation 3(2) requires an exporter of services to furnish EDF within 30 days from the end of the month in which the invoice for services is raised. RBI Notification EDF_13.01.26

Monthly Consolidation

An exporter may submit one EDF covering all services exported to one or more recipients during a month. RBI Notification EDF_13.01.26

This facilitates consolidated monthly reporting rather than necessarily requiring a separate EDF for each invoice.

Services other than Software

The Regulations separately provide that an exporter of services other than software may submit an EDF on or before the date of receipt of payment. RBI Notification EDF_13.01.26

This provision needs to be read together with the general 30-day requirement. Operational implementation should accordingly be aligned with the applicable regulatory guidance and the process followed by the relevant AD Bank.

Delayed Submission

Where there is a delay in submission of EDF, the AD Bank may extend the period on a request from the exporter explaining the reasons for the delay, after satisfying itself regarding the reasonableness of the request. RBI Notification EDF_13.01.26

What Happens to SOFTEX?

From 1 October 2026, software is expressly included within the definition of services, and EDF becomes the prescribed declaration for export of services.

Accordingly, software exports transition from the existing SOFTEX declaration mechanism to EDF. RBI Notification EDF_13.01.26 RBI Notification EDF_13.01.26

However, this does not mean that STPI ceases to have a role.

For software exports from the Domestic Tariff Area, the 2026 Regulations recognise the AD Bank or STPI as the specified authority. For services other than software from the DTA, the specified authority is the AD Bank. RBI Notification EDF_13.01.26

Thus:

SOFTEX as the declaration mechanism gives way to EDF, while STPI continues to be recognised within the regulatory framework for software exports.

The New EDF — Designed for Service Exports

The EDF prescribed under the 2026 Regulations itself reflects the wider scope of the new reporting framework.

The form captures exporter details, IE Code, GSTIN, PAN, AD Bank particulars and other export information. RBI Notification EDF_13.01.26

Significantly, Part 2B — “Details of Export Value of Services” specifically captures details such as:

• overseas recipient;
• invoice number and date;
• currency and invoice amount;
• net realisable value;
• contract details;
• description of services; and
• Service Accounting Code (SAC).

It also accommodates reporting relating to multiple recipients. RBI Notification EDF_13.01.26

EDF and EDPMS — A More Structured Compliance Trail

An important feature of the new regime is the integration of service-export declarations with the Export Data Processing and Monitoring System (EDPMS).

The AD Bank is required to enter details of EDF relating to services into EDPMS within five working days of receiving the EDF from the exporter. RBI Notification EDF_13.01.26

The AD Bank is also required to monitor transactions in EDPMS for closure of outstanding entries and follow up with exporters for the necessary documentation. RBI Notification EDF_13.01.26

For service exporters, the compliance trail therefore becomes increasingly structured:

Export Invoice → EDF → EDPMS → Realisation → Closure

For non-software service exporters who were generally outside the prescribed export-declaration framework, this is one of the more significant practical consequences of the new Regulations.

EDF Filing and Realisation — Two Separate Obligations

Exporters should distinguish between:

Furnishing the EDF, and
Realising and repatriating the export proceeds.

These are separate FEMA obligations.

Under the 2026 Regulations, as amended in September 2026, export proceeds relating to services are generally required to be realised and repatriated within nine months from the date of invoice. RBI Notification EDF_13.01.26

The AD Bank may, upon a request from the exporter and after satisfying itself regarding the reasons, permit an extension beyond the prescribed realisation period. RBI Notification EDF_13.01.26

Accordingly, submission of EDF does not by itself discharge the exporter's obligation to monitor timely realisation and repatriation of export proceeds.

Who Should Take Note?

The new framework is relevant to a wide range of Indian service exporters, including:

Software and IT/ITES businesses | SaaS companies | Professional service firms | Consultants | Engineering and design businesses | Marketing and digital agencies | Freelancers | Other businesses providing services to overseas customers

The compliance impact will, however, differ.

Software exporters should prepare for the transition from the established SOFTEX process to EDF and understand the operational procedure applicable through their AD Bank/STPI.

Other service exporters should assess the impact of coming within a recurring EDF reporting framework and the consequential EDPMS monitoring of export receivables.

What Should Service Exporters Do?

With the new Regulations becoming effective from 1 October 2026, businesses should consider:

1. Mapping their service exports and distinguishing software from other services.

2. Identifying the applicable specified authority — AD Bank, STPI or SEZ Development Commissioner, as applicable.

3. Reviewing the invoicing process to identify and consolidate export invoices for EDF reporting.

4. Establishing internal responsibility for EDF preparation, submission and follow-up.

5. Coordinating with the relevant AD Bank/STPI on the operational mechanism for implementing the new requirements.

6. Reconciling export invoices, GST records, EDF reporting, bank realisations and EDPMS entries.

7. Separately monitoring the applicable nine-month realisation period.

8. Establishing a process for timely follow-up and closure of outstanding EDPMS entries.

SSB Perspective

The 2026 Regulations represent a significant change in FEMA reporting for export of services.

For software exporters, the change is principally a recasting of an existing compliance framework — from SOFTEX to EDF.

For many other service exporters, the impact is more fundamental: transactions that generally did not require a prescribed export declaration will now enter the EDF and EDPMS reporting framework.

While monthly consolidated EDF reporting provides an element of administrative convenience, EDPMS integration is likely to bring greater visibility to outstanding service-export receivables and require closer reconciliation between invoices and foreign exchange realisations.

Businesses should therefore view the new requirement not merely as another FEMA filing. An effective compliance process should connect:

Export Invoice → EDF Reporting → EDPMS → Bank Realisation → Reconciliation → Closure

As the new framework becomes operational, exporters should also monitor implementation procedures and guidance from RBI, AD Banks, STPI and other specified authorities.

Regulatory Sources

New framework:
Reserve Bank of India — Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB dated 13 January 2026, as amended up to 22 September 2026. RBI Notification EDF_13.01.26

Existing framework referred to for comparison:
Reserve Bank of India — Foreign Exchange Management (Export of Goods & Services) Regulations, 2015, Notification No. FEMA 23(R)/2015-RB, as amended up to 5 June 2026. The existing SOFTEX and export-document procedures are contained in clauses 6B, 6C and 10. RBI Notification EDF_05.06.26(1) RBI Notification EDF_05.06.26(1)

Publication Details

Publication: SSB FEMA Insights
Reference: SSB-FEMA-2026-001
Published by: SSB & Associates, Chartered Accountants
Author: SSB Editorial Team
Reviewed by: CA C S Sreenivas, Partner
Publication Date: 30th September 2026

Disclaimer

This publication is intended for general informational purposes only and does not constitute professional advice, recommendation or solicitation. The information is based on the law and regulatory position available as on the date of publication. Readers should seek appropriate professional advice having regard to their specific facts and circumstances.