What replaces SOFTEX on 1 October 2026, and what must I file?

What exactly changes on 1 October 2026?

The instrument is Notification No. FEMA 23(R)/2026-RB, dated 13 January 2026 , the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. It comes into force on 1 October 2026 and supersedes the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015 (Notification No. FEMA 23(R)/2015-RB). Three things follow from it for anyone who files a SOFTEX today.

Note what is not in that table. The commencement date is a cliff for several other rules at the same time, and this guide deliberately does not restate them. See section 7.

Who certifies my software export now?

This is the change that will actually alter how a software exporter works, and it gets less attention than the retirement of the form. The 2026 Regulations set the specified authority by category of export . The table below states the position for exports from the Domestic Tariff Area . If you export from a Special Economic Zone, see section 7 before assuming it applies to you.

If your AD bank is already the party matching your inward remittances and issuing your realisation documents, consolidating certification with it removes a handoff. That is a reason to ask your bank what it intends to offer, well before the date, rather than a reason to assume it will offer anything. Whether a particular bank is ready to certify software exports on 1 October is a question for that bank.

Which declarations fall either side of the date?

The 2026 Regulations come into force on 1 October 2026. Until then the 2015 Regulations are in force and SOFTEX is the form. That gives a clean rule for the next few weeks and an untidy one for anything already open.

• A declaration due before 1 October 2026 is made under the 2015 Regulations, on SOFTEX. File it on time and on the old form.
• A declaration due on or after 1 October 2026 falls under the 2026 Regulations and the single EDF.
• A SOFTEX filed before the date but still open was validly made and the obligation it records survives the form. The entry still has to be matched to its inward remittance and closed.

Did the EDF not already replace SOFTEX in 2013?

No. This comes up often enough to be worth stating precisely, because an exporter who believes the change already happened will read the 2026 notification as housekeeping and do nothing.

A.P. (DIR Series) Circular No. 43 dated 13 September 2013 (RBI/2013-14/254) , in force from 1 October 2013 , introduced the EDF. What it actually did was narrower than the shorthand suggests:

• It replaced the GR and PP forms , and it did so for non-EDI ports only .
• It expressly left the SDF applicable as before at EDI ports .
• It kept SOFTEX as a separate common form for single and bulk software exports.

So the 2013 EDF and the 2026 EDF are not the same event, and the 2013 one did not touch software declarations at all. The date the two changes share (1 October, thirteen years apart) is probably what fuses them in people's memory. Any source telling you SOFTEX was folded into the EDF in 2013 is describing the GR/PP replacement and has the software limb wrong.

What happens to my circular citations?

The 2026 Regulations consolidate 167 prior A.P. (DIR Series) circulars, together with the 2015 Regulations, into a single framework. That is a larger administrative event than the form change for anyone who maintains written procedures.

The practical exposure is not the regulations themselves but everything that points at them. A compliance SOP that says "as required by A.P. (DIR Series) Circular No. X", a template reply to a bank query, a checklist a junior colleague works from, an internal wiki page. Each of those is a pointer into a document that is superseded on 1 October 2026. The pointer does not break loudly. It simply starts citing something that no longer governs, and nobody notices until a bank or an auditor asks.

• Search your own documentation for "A.P. (DIR Series)" and for "Master Direction" , and list what comes back before the date rather than after it.
• Treat every hit as needs re-checking rather than wrong. Most of the substance is consolidated, not abolished. But the citation has to be re-pointed, and whether the substance survived is a question you answer per rule.
• Do the same for anything that cites Master Direction 16/2015-16 (Export of Goods and Services) or 17/2016-17 (Import of Goods and Services).

What should I do before 1 October?

Five things, in the order they are worth doing. None of them depends on detail that is still unsourced.

1. File what is due, on the current form. Clear every SOFTEX declaration falling due up to 30 September under the 2015 Regulations. This is the only item with a hard deadline attached.
2. Close what you can close. Match open declarations to the remittances that pay them, so that as few entries as possible cross the date unresolved. An entry you carry across is an entry you will be reconciling under one framework against paperwork raised under another.
3. Ask your AD bank what it will offer. The software row gives you a choice between an Authorised Dealer and STPI. Whether your bank is ready to take that role, and on what terms, is knowable only by asking it.
4. Inventory your citations. Per section 5. Before the date, so the list is a migration task rather than an audit finding.
5. Do not rewrite procedures around unsourced detail. Several widely repeated claims about the new framework are not in the notification text. Section 7 names them.

Which parts does this guide not state, and why?

The 2026 Regulations have attracted a large volume of commentary, and a good deal of it asserts operational detail that the notification itself does not carry. Those assertions may well turn out to be right. They are not stated here, because a page that guesses at mechanics is worse than a page that says it does not know. An exporter can work around a gap, but not around a confident wrong answer.

• The realisation period from 1 October 2026. The period for realisation and repatriation is a separate rule with its own history, and it changes at the same commencement date. This guide states no figure for it. Read when the realisation clock actually starts and confirm the post-cutover period with your AD bank before computing any deadline that runs past 30 September 2026.
• The specified authority for exports from an SEZ. The table in section 2 states the position for the Domestic Tariff Area only. The 2026 Regulations define the specified authority separately for Special Economic Zones, and this guide does not state that limb. An SEZ software exporter should not read the DTA row as licensing a move to an AD bank. Confirm your own position before changing anything.
• Whether monthly consolidated filing replaces transaction-level declarations. Widely asserted in practitioner commentary; not in the notification text. No filing frequency is stated here.
• The position of non-STP units and individual freelancers. A real question with a real population behind it, and one this guide cannot answer on sourced material.
• Penalty exposure under the new framework. What a contravention costs is a compounding question. No figure is stated here.
• The EDF's own fields and annexures. What the single form looks like, field by field, is not described here. When the operationalising annexure is published this guide will be updated against it.

Frequently asked questions

Does the SOFTEX form still exist after 1 October 2026?

No. The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. Notification No. FEMA 23(R)/2026-RB dated 13 January 2026. Come into force on 1 October 2026 and supersede the Export of Goods and Services Regulations, 2015. Under the 2026 Regulations a single Export Declaration Form covers goods, services and software, and the separate SOFTEX form is not carried forward. Until 30 September 2026 the 2015 Regulations are still in force and SOFTEX is still the form, so a declaration due before the changeover is a SOFTEX declaration and should be filed as one rather than held back for the new form.

Who certifies my software export once SOFTEX is gone?

An Authorised Dealer bank or STPI. For exports from the Domestic Tariff Area the 2026 Regulations set the specified authority by category: the Commissioner of Customs for exports of goods, an Authorised Dealer for services other than software, and an Authorised Dealer or STPI for software. The practical change is that STPI stops being the only route for a software exporter. An exporter who has been sending every invoice through an STPI office because there was no alternative now has one, and the choice is a commercial and operational decision rather than a compliance requirement. The 2026 Regulations define the specified authority separately for Special Economic Zones, and that limb is not stated in this guide.

What happens to a SOFTEX I filed before 1 October 2026 that is still open?

The declaration was validly made under the regulations in force when it was filed, and the export obligation it records does not disappear because the form was retired. What changes is the framework the entry is administered under from 1 October 2026 onward. Treat an open pre-cutover entry as ordinary unfinished business: match the inward remittance to the declaration, get the bank to record realisation, and close it. Do not assume the changeover closes anything on its own, and do not assume an open entry is forgiven because the form no longer exists.

Did the EDF not already replace SOFTEX back in 2013?

No, and this is a common and expensive confusion. A.P. (DIR Series) Circular No. 43 dated 13 September 2013 (RBI/2013-14/254), in force from 1 October 2013, introduced the EDF to replace the GR and PP forms, and it did so for non-EDI ports only. It expressly left the SDF applicable as before at EDI ports, and it kept SOFTEX as a separate common form for single and bulk software exports. So the 2013 change did not touch SOFTEX at all. The replacement of SOFTEX by a single EDF happens on 1 October 2026, and any page or adviser telling you it already happened in 2013 is describing a different change.

How many circulars does the 2026 framework consolidate?

One hundred and sixty-seven. The 2026 Regulations consolidate 167 prior A.P. (DIR Series) circulars along with the Export of Goods and Services Regulations, 2015 into a single framework. The consequence for anyone maintaining a compliance file is that a citation to an individual pre-2026 circular becomes a pointer into a document that has been superseded. Any internal SOP, bank correspondence template or checklist that cites a specific circular by number needs re-checking against the 2026 Regulations rather than being assumed to carry over.

Should I wait until 1 October to file a declaration that is due in September?

No. The 2015 Regulations bind a declaration due before 1 October 2026, and a late filing is a contravention whether or not a new form is about to arrive. Filing on time under the old form is correct; holding a September declaration back so it can be made on the new form creates a delay you have to explain and gains nothing. The same applies in the other direction: do not try to pre-file on a form that has no legal effect until the commencement date.

Update history

• 2026-09-17 First published.