SOFTEX is gone. The EDF is here: what service exporters file now, and by when

The EDF replaces SOFTEX for exports made from 1 October 2026. Where a remittance exceeds ₹10 lakh, a company, LLP, firm or other non-individual files a monthly EDF, due 30 days after the month ends. Resident individuals, and others at ₹10 lakh or less, are deemed to have filed once the bank has the payment details.

01What changed on 1 October 2026?

One form now covers goods, services and software, and proceeds must come in within 9 months of the invoice date. For years, software exporters filed SOFTEX forms and other service exporters filed nothing. That has ended.

The rules sit in the FEMA (Export and Import of Goods and Services) Regulations, 2026. This is how the two forms compare.

The cutover should follow the export date. Exports up to 30 September 2026 should stay on SOFTEX, even if filed in October. Confirm with STPI or your bank.

Three notifications make up the position today.

The third one matters most. It was notified on 2 November, but it applies from 1 October. An explainer that says every service exporter must file monthly is out of date.

03What is the EDF deadline, and what goes in it?

For October 2026 invoices, the EDF is due on 30 November 2026. As a rule, it is due 30 days after the end of the month in which you raise the invoice. An invoice dated 22 October is due 30 November, because the count starts from month-end, not invoice date.

One form can cover every invoice and every client for the month. It has two parts. The first part holds your details, including PAN. Part 2B has one row per invoice with the SAC code, description, currency, value and Net Realisable Value. One invoice is one row, however many instalments arrive. A month with no invoices needs no filing.

The bank enters the form into EDPMS within 5 working days. EDPMS is the RBI's system that banks use to track the export and its payment. You never log in to it. The EDF is your declaration. EDPMS is the bank's record of it.

Two timing rules to remember.

• Software exporters have no pay-date option. The 30-day rule applies, though the bank can extend it on a request that gives reasons.
• Other service exporters may file on or before the day the payment arrives instead.

Bank templates and channels vary, and there is no universal portal. Ask your bank what it uses before the month closes.

05What do the rules mean in real situations?

They mean different things for a freelancer, a growing company and a client who pays late. Here are four cases.

There are two separate ₹10 lakh tests, and people mix them up. The deemed EDF is judged on the inward remittance. Closing an entry, or reporting a reduction or non-payment, on your own declaration (Regulations 4(2) and 6) is judged on the invoice value, not the unpaid balance.

For the currency side of a late payment, see our note on cross-border cash and the rupee.

07What should you do this week?

Five things, in this order.

1. Ask your bank, in writing, how it treats sole proprietors, software exporters and part-payments under the Second Amendment.
2. For October 2026 invoices, file the EDF by 30 November if you are not a resident individual and expect a remittance above ₹10 lakh.
3. On every receipt under the deemed route, give the crediting bank the payment details and keep the evidence.
4. Build a receivables register with a due date for each invoice, and quote the invoice number on every remittance.
5. Raise any extension, set-off or reduction request before the due date, not after.

09Frequently asked questions

What replaced SOFTEX?

The Export Declaration Form (EDF) replaced SOFTEX for software exports made on or after 1 October 2026. Exports up to 30 September 2026 should stay on SOFTEX, even if filed in October. Confirm with STPI or your bank.

Do freelancers have to file an EDF?

A resident individual is deemed to have filed the EDF by giving the crediting bank the payment details, at any value. A sole proprietor is likely covered, but confirm with your bank.

What is the EDF deadline?

Where a monthly EDF is required, it is due 30 days after the end of the invoice month. October 2026 invoices are due on 30 November 2026. The date is on our November 2026 compliance calendar.

Is there a penalty for not filing the EDF?

We found no fixed fine for a missed EDF. The exposure comes from FEMA section 13 (up to three times the sum involved), GST Rule 96A if you export under LUT, and follow-up by your bank.

Where do I file the EDF?

With your authorised dealer bank, ideally the one where the proceeds settle. Software exporters can use STPI instead, and SEZ units file with the SEZ Development Commissioner. You do not file the EDF on any RBI portal.

How long do I have to receive payment?

Nine months from the invoice date, or 12 months if the invoice or settlement is in INR. The bank can extend the period if you ask and give reasons. Ask before the due date.

A form is a small thing. What it creates is a record that your bank, your GST refund file and your ledger all have to agree on. The exporters who struggle will not be the ones who filed late. They will be the ones whose three records tell three different stories.

To get the register built and your bank's answers in writing before 30 November, start with our company secretarial and compliance work. Our controllership practice keeps the ledger in step with the bank's record, and our FEMA and RBI work covers the other cross-border filings.

Current as at 6 November 2026. General guidance, not legal, tax or investment advice. Confirm the position with your authorised dealer bank and the RBI notifications before acting.