SOFTEX Filing Due Dates, Process and Penalties Before the EDF

SOFTEX filing ended on 1 October 2026, when the Export Declaration Form (EDF) replaced it under the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, made under the Foreign Exchange Management Act, 1999 (FEMA). SOFTEX filing was how software exporters declared each overseas sale to the Reserve Bank of India (RBI). For an invoice raised from October onwards, check the EDF guide for service exporters.

This software export declaration went through Software Technology Parks of India (STPI) or the special economic zone (SEZ) authority, and that record was what let the payment be matched to the export. You can read what the SOFTEX form was and what replaced it.

How that filing worked while it ran still matters: who filed where, the 30-day deadline, the steps, the Non-STP route and the penalties for filing late. You still need those details if you have September 2026 invoices left to declare, if you are filing a SOFTEX late now, or if one was filed late or never filed at all.

The date on the export invoice you raised to your overseas client decides which rules apply to you. The 2026 regulations took effect on 1 October 2026, and RBI Circular 20 superseded the SOFTEX circulars, so nothing raised from that day goes through SOFTEX filing.

For anything in the second row, follow the EDF guide for service exporters. For the first row, the SOFTEX steps and deadlines below still apply.

SOFTEX applicability by unit type before the switch

SOFTEX applied to software exported in non-physical form, such as code delivered online and cloud software products. Three kinds of unit filed it, and each one took a slightly different route to the same certificate.

The RBI's SOFTEX page limited the form to software, so services that were not software had no SOFTEX route.

IT-enabled services (ITeS), such as BPO, call centres and back-office work, were outside SOFTEX. The RBI's SOFTEX page said the form "does not include export of services using IT as a tool i.e. ITeS". Under the old Master Direction (para B.7), a service with no specified form could be exported without any declaration, but the money still had to be realised and brought into India through the AD bank.

From 1 October 2026 that changed: ITeS exporters file the EDF like other service exporters.

Older STPI guidance, such as the STPI Bengaluru FAQ, spoke of "IT/ITES exports" together, so if your centre once certified ITeS forms for you, confirm its position in writing.

The process ran the same way for STP and Non-STP units, with registration as the only extra step for a Non-STP unit. Most exporters, or their chartered accountant (CA), worked through these seven steps, in this order, for each invoice or batch. This is how SOFTEX filing was done online up to 30 September 2026.

1. Completed Non-STP unit registration - A unit outside an STP or SEZ registered with its STPI centre first. Under STPI Bengaluru's procedure the certificate lasted three years and had to be renewed.
2. Registered export contracts - Each export contract was registered with STPI before a SOFTEX could be filed against it, so the declared value had an agreement behind it.
3. Generated the SOFTEX number - The exporter generated a SOFTEX number online on the RBI SOFTEX facility for each transaction, entering its details and the type of export.
4. Prepared the declaration form - The form carried the exporter and buyer details, the invoice value and currency, a description of the software and the AD bank that would receive the money.
5. Uploaded supporting documents - The invoice, the contract, the SOFTEX number and a datacom or internet bill went with the form, showing the work had actually gone offshore.
6. Submitted within the deadline - The form went to STPI or the SEZ authority within 30 days of the invoice, or of the last invoice for a monthly batch.
7. Got certification and routed to the bank - The authority checked and certified the form, then a certified copy went to the AD bank that received the payment.

The value, currency and description had to match across the invoice, the form and the bank credit.

Where exporters logged in to file SOFTEX

Exporters used two online places. The SOFTEX number came from the RBI SOFTEX facility on the RBI website, which asked for the exporter name, Importer Exporter Code (IEC), address, export type and whether the form was single or bulk. Unit registration and online submission ran through STPI's own login at stpionline.stpi.in.

STPI Bengaluru also accepted a soft copy or a hard copy in quadruplicate. Check with your STPI centre whether it still accepts the filing, and how.

What STPI certified and what the bank did next

STPI, or the SEZ authority, checked the form against the invoice, contract and evidence of offshore delivery, then certified the export value. This STPI SOFTEX certificate was the official record that your software export had happened at the value you declared.

The certified copy then went to your AD bank. The bank matched it against the inward payment when the money arrived and reported the export, so the entry in the RBI's Export Data Processing and Monitoring System (EDPMS) could be closed. Until both halves met, the entry stayed open.

The SOFTEX filing due date was 30 days from the date of the invoice. A monthly batch was due 30 days from the month's last invoice. These rules governed software exports invoiced before 1 October 2026. For one still unfiled after that date, the old clock applies only on a reasonable reading of the saving clause.

The date mattered because the certified form was what let your AD bank match the invoice to the payment and close the export record. A missed date left that record open. The payment must also be realised within nine months of the invoice, or 12 months if invoiced or settled in INR.

From 1 October 2026 the clock is different. An EDF for software is due 30 days from the end of the month in which you raised the invoice, so the count starts at month end rather than on the invoice date. Your AD bank can extend that period on a reasoned request.

Worked due dates for September and October 2026 invoices

Worked due dates make the two clocks easier to compare around the changeover. The September rows assume the old SOFTEX clock still applies, so treat them as guidance until your bank or STPI confirms.

If your September deadline has already passed, the late-filing rules apply to you rather than this table.

September 2026 invoices still not filed: which deadline applies now?

No RBI rule deals with invoices raised before 1 October that were still undeclared on that date. The 2026 regulations replaced the 2015 regulations "except in respect of things done or omitted to be done before such supersession", and that general saving clause is the only text you have to go on.

A reasonable reading is that an invoice raised up to 30 September 2026 keeps its old 30-day clock, which makes 30 October 2026 the last date that clock can reach. This is a reading rather than a ruling, so confirm the dates in writing with your AD bank or STPI.

• Before your old date - ask your STPI centre whether it still certifies SOFTEX filings for September invoices, and its cut-off date.
• If your bank wants an EDF - file it on the EDF clock instead, which for a September invoice runs to 30 October 2026.
• Once the date has passed - the old fix was condonation of the delay by the regional RBI office.

How monthly bulk filing worked under SOFTEX

Monthly bulk filing let you declare a month of invoices on one SOFTEX rather than one form per invoice. It was optional. The deadline moved with it, to 30 days from the date of the last invoice in that month.

The SOFTEX number had a bulk option too, up to 200 forms at a time on the RBI facility. Large exporters, with turnover of at least ₹1,000 crore or at least 600 forms a year, were allotted a yearly block of numbers instead, and their bulk statement ran to the close of the month.

Non-STP units were exporters outside an STP or SEZ, which covered many SaaS firms and smaller software companies. Before filing a single SOFTEX, a unit like this had to register with its jurisdictional STPI centre as a Non-STP unit, after which it filed exactly as an STP unit did.

STPI Bengaluru's published procedure set out the terms for that registration. Other STPI centres ran their own versions, so details could differ by centre.

From 1 October, a Non-STP certificate is not a stated requirement for filing an EDF through your AD bank. The regulations name STPI as one place you may file, not the only one, so confirm with your bank before you renew a registration you may no longer need.

The SOFTEX late filing penalty still matters, because a late or missing SOFTEX does not disappear just because the form changed. The export entry for that invoice stays open in EDPMS until a valid declaration is matched to the payment.

The steps that fixed a late SOFTEX depended on STPI SOFTEX certification and the RBI regional office. If you have one outstanding, act on it now rather than waiting for a notice.

• List every open invoice - note the date, value and whether payment has arrived, so you know which entries are still open.
• Ask your AD bank first - it holds the EDPMS entry and can tell you whether it wants a late SOFTEX or an EDF.
• Get help from a CA - if the amounts are large or the delay is long, before you write to any authority.

Condonation of delay for a late SOFTEX

Under STPI Bengaluru's published procedure, STPI did not accept a SOFTEX filed after the 30-day window on its own. You first had to approach the regional RBI office and get the delay condoned, which means formally excused, and only then submit the form to STPI with the condonation attached.

STPI's downloads page still lists the formats exporters used: a condonation letter, an AD bank certificate confirming the payment was realised, a CA certificate for the offshore export, and an exporter declaration explaining the delay. Ask your STPI centre whether it still processes condonation cases for old invoices.

For an EDF, there is no separate condonation step. You ask your AD bank to extend the filing period and give your reason. Under the 2026 regulations the bank cannot charge you a penalty for the delay, although that protects you from the bank's charges, not from FEMA.

FEMA Section 13(1) penalty and how compounding works

FEMA Section 13(1) sets the ceiling for a missed declaration. Once a contravention is adjudicated, the penalty can reach three times the sum involved where that amount can be worked out, or up to ₹2 lakh where it cannot. A further amount can be charged for each day the contravention continues.

Those are maximums, imposed only after adjudication, and a case can be settled through compounding instead. Compounding means admitting the contravention and paying a sum to close it without a penalty order. Under the Foreign Exchange (Compounding Proceedings) Rules, 2024, it works like this:

• Application fee - ₹10,000 plus GST, paid when you apply to the RBI.
• Decision - the RBI aims to pass a compounding order within 180 days of a complete application.
• Payment - the compounded amount is due within 15 days of the order.
• Exclusions - compounding is not available where the amount involved cannot be quantified, or where a Section 13 penalty has already been imposed.
• Repeat cases - a similar contravention cannot be compounded again within three years of an earlier compounding.

Most SOFTEX problems came from small slips that repeated every month. The same slips can now catch you during the switch to the EDF, alongside two new ones.

The declaration, SOFTEX before or EDF now, is filed by you, your CA or your STPI consultant. Xflow sits on the payment side of the same export, where the money arrives and the proof of that payment is produced.

Xflow is a cross-border payments platform for Indian exporters that collect from clients abroad:

• Receiving accounts - collect from clients in 25+ currencies, with settlement to your Indian bank account by the next business day (T+1).
• eFIRA on every withdrawal - an eFIRA issued by an AD Category I bank, downloadable within 24 hours of each withdrawal.
• Authorised by the RBI - Xflow Payments India Private Limited holds final Payment Aggregator - Cross Border (PA-CB) authorisation from the RBI as of February 2026. Final means the fully approved stage, past in-principle, and Xflow is ISO 27001 and SOC 2 certified.

Before you file, confirm the current rules with your AD bank, your STPI centre or your chartered accountant.