RBI Export Rules from 1 October 2026: EDF Replaces SOFTEX for Software Exports

The Reserve Bank of India (RBI) has introduced a new framework for the export and import of goods and services under the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. The new framework will come into force from 1 October 2026 and will replace the existing export and import regulations and reporting framework.

One of the most significant changes is the introduction of a uniform Export Declaration Form (EDF) for exports of goods, services and software. For software and IT/ITeS exporters, this means a major change from the existing SOFTEX-based reporting framework.

What is changing from 1 October 2026?

The new RBI framework is intended to simplify India's foreign exchange compliance system by bringing the export of goods, services and software under a more unified reporting and monitoring structure.

The key changes include:

• A common Export Declaration Form (EDF) framework for goods, services and software.
• Replacement of the existing SOFTEX form framework for software exports.
• Simplified and consolidated EDF filing for service and software exports.
• Greater responsibility and operational flexibility for Authorised Dealer (AD) banks.
• Recognition of third-party receipts and payments, subject to AD bank satisfaction regarding the bona fides of the transaction.
• Revised rules relating to realization and repatriation of export proceeds.
• Greater use of digital processes, including the RBI's PRAVAAH platform for applications to the RBI where applicable.

1. One EDF for goods, services and software

Under the new regulations, exporters of goods and exporters of services are brought within a common declaration framework through the Export Declaration Form (EDF). The definition of services also covers software for the purposes of the new regulations.

This is an important shift from the earlier framework, where different reporting mechanisms existed for goods and software exports. The new approach seeks to standardise the declaration of export value and improve monitoring of export transactions.

Type of export	New reporting approach
Goods	EDF is furnished at the time of export. For goods exported through an EDI port, the EDF is deemed to be submitted as part of the shipping bill.
Services	EDF is generally required within 30 days from the end of the month in which the invoice is raised, subject to the specific provisions applicable to the exporter.
Software	Software exports move to the common EDF framework instead of the existing SOFTEX form framework.

2. What happens to SOFTEX?

For software exporters, this is one of the most important changes.

Under the existing framework, exports of software transmitted electronically are reported through the SOFTEX form. The process has historically involved valuation and certification through the designated authorities, including the Software Technology Parks of India (STPI) framework.

From 1 October 2026, the new FEMA framework replaces the separate SOFTEX reporting form with the Export Declaration Form (EDF).

Importantly, this does not mean that every software-related authority or process disappears. The 2026 regulations continue to recognise specified authorities for software exports, including AD banks, STPI and the Development Commissioner of an SEZ, as applicable.

3. Consolidated EDF for service and software exports

The new framework provides a significant simplification for businesses having multiple export invoices.

An exporter of services who has made exports to one or more recipients during a month may submit a single EDF covering those exports, subject to the applicable requirements.

For services and software, the general reporting timeline is linked to the month in which the invoice is raised. The EDF is generally required within 30 days from the end of that month.

For services other than software, the regulations also provide an option to submit the EDF on or before the date of receipt of payment.

Particular	Position from 1 October 2026
Multiple service invoices	May be consolidated into a single EDF for exports made during the month, subject to the regulations.
Software exports	Covered under the common EDF framework instead of the existing SOFTEX form.
General service EDF timeline	Within 30 days from the end of the month in which the invoice is raised.

4. Revised realization period for export proceeds

The new regulations also provide a revised framework for realization and repatriation of export proceeds.

For ordinary exports, the prescribed period under the 2026 framework is generally 15 months from the relevant date. For exports invoiced in Indian rupees and subject to the applicable conditions, the period can extend to 18 months.

Businesses should therefore avoid treating the realization period merely as an accounting or banking follow-up matter. Outstanding export receivables need to be tracked against the applicable FEMA timeline and the corresponding EDPMS records.

5. Special rule for goods sent to overseas warehouses

A specific change is relevant for exporters who send goods to an overseas warehouse before making the final sale.

Under the 2026 framework, the realization period for goods sent to an overseas warehouse is linked to the date of sale from the warehouse, rather than simply the date on which the goods leave India. The applicable period is generally 15 months from the date of sale.

6. Third-party payments for export transactions

The 2026 framework provides greater flexibility for third-party receipts and payments.

An Authorised Dealer may permit third-party receipts or payments for export and import transactions where it is satisfied about the bona fides of the transaction.

This is particularly relevant where the overseas customer, contracting entity and actual remitting entity are not the same. Exporters should ensure that the commercial documents, invoice, contractual arrangements and banking records clearly support the transaction.

The third-party details should also be appropriately disclosed in the applicable export documentation wherever required.

7. Greater responsibility for Authorised Dealer banks

The new framework places greater responsibility on Authorised Dealer banks for monitoring export and import transactions.

AD banks are expected to maintain appropriate internal policies and procedures for handling trade transactions and to monitor outstanding export transactions, realization of export proceeds and closure of relevant entries.

The framework also gives AD banks greater operational authority in areas such as extensions, reduction in export value, set-off of export receivables against import payables and third-party receipts and payments, subject to the conditions prescribed under the regulations and directions.

Area	Practical implication for exporters
EDF filing	Export declarations need to be filed under the new EDF framework.
Export realization	Outstanding receivables need to be tracked against the applicable FEMA timeline.
Third-party receipts	The AD bank must be satisfied about the bona fides of the transaction.
Closure of export entries	Exporters should ensure timely submission of realization evidence and reconciliation with bank records.

8. Digital compliance and PRAVAAH

The new framework also continues the move towards digital and system-based regulatory compliance.

Where an exporter or importer needs to approach the RBI for regulatory approval or permission, the applicable process is routed through the RBI's PRAVAAH platform.

For businesses, the broader message is clear: FEMA compliance is increasingly becoming a data and reconciliation exercise involving invoices, shipping documents, bank credits, export declarations and system records.

9. What should IT and ITeS companies do before 1 October 2026?

Software companies and IT/ITeS exporters should prepare for the transition rather than waiting until the new framework becomes operational.

• Review the existing SOFTEX process: identify all activities currently dependent on SOFTEX filing, certification and closure.
• Map the new EDF process: identify who will prepare, submit and reconcile the EDF under the new framework.
• Review invoice data: ensure invoice number, invoice date, currency, value, recipient and service/software details are readily available.
• Reconcile export receivables: match invoices with inward remittances and identify old outstanding balances.
• Review third-party payment arrangements: document the commercial reason and contractual basis wherever the remitter is different from the overseas customer.
• Coordinate with the AD bank: understand the bank's implementation process, documentation requirements and internal cut-off dates.
• Update internal SOPs: align finance, accounts receivable, treasury and compliance teams with the new reporting framework.

10. What should exporters of services do?

Service exporters should pay particular attention to the new monthly consolidation mechanism.

Businesses with a large number of overseas invoices should consider creating a monthly export-compliance process under which all relevant invoices are identified, grouped, declared through EDF and subsequently reconciled with the foreign currency realization received through the banking channel.

A simple monthly control can include:

• Total export invoices raised during the month.
• EDF filed for the month.
• Invoices covered by the EDF.
• Foreign currency realization received.
• Outstanding export receivables.
• EDPMS status and pending entries.
• Exceptions requiring AD bank follow-up.

11. Key difference: old framework vs new framework

Particular	Existing approach	From 1 October 2026
Software export declaration	SOFTEX framework	Unified EDF framework
Service exports	Different declaration/reporting treatment depending on the nature of export	EDF-based declaration
Monthly consolidation	More fragmented reporting processes	Single EDF may cover multiple service/software exports during a month
Third-party payments	Subject to the earlier framework and applicable conditions	Expressly recognised subject to AD bank satisfaction regarding bona fides
AD bank role	Monitoring under the existing framework	Greater responsibility and delegated operational authority

12. The practical impact on exporters

The new RBI framework should not be viewed merely as a change in the name of an export form.

For businesses, the real change is the move towards a single, integrated export-compliance process. Invoice generation, export declaration, bank realization, EDPMS records and closure should increasingly be treated as connected parts of the same compliance cycle.

For software and IT/ITeS companies, the discontinuation of SOFTEX is particularly significant. Finance and compliance teams should ensure that their systems and internal controls are capable of generating the information required for EDF filing and subsequent reconciliation.

Disclaimer: This article is intended for general informational purposes and should not be treated as legal, regulatory or professional advice for a specific transaction. Exporters should review the applicable RBI regulations, directions and their Authorised Dealer bank's implementation requirements before taking action.