SOFTEX ends on 30 September, and the new clock is nine months

Summary

From 1 October 2026 a software exporter stops filing SOFTEX and, like every other exporter of services, declares on the EDF within 30 days from the end of the month in which the invoice was raised. And the realisation period that the new Regulations were going to raise to 15 months was cut back to nine months (twelve for rupee invoices) by an RBI amendment dated 22 September 2026, before the Regulations took effect.

The situation

A Pune software house raising monthly invoices on a US client has filed SOFTEX for years and planned its collections around the 15 months that every explainer since January said would apply from 1 October. The form goes on 30 September. The 15 months never arrives: RBI amended the Regulations eight days before they commence, and most commentary, including my own tool, still carries the old figure.

The rule

The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification FEMA 23(R)/2026-RB, 13 January 2026) come into force on 1 October 2026 and supersede the 2015 Regulations. RBI's notification page, as amended up to 22 September 2026, does not mention SOFTEX anywhere.

The declaration. Regulation 3 requires an exporter of services to furnish "a declaration in EDF specifying the amount representing the full export value of services, within 30 days from the end of month in which invoice for services has been raised". One EDF may cover all recipients invoiced in the month. Exporters of services other than software may instead submit it on or before the date they receive payment. The specified authority is the AD bank for services other than software, and the AD bank or STPI for software.

The realisation period. Regulation 5 now reads nine months from the date of shipment (goods) or the date of invoice (services), nine months from the date of sale for goods exported to a warehouse outside India, contract terms for project exports, and twelve months where the export is invoiced or settled in Indian rupees. Each of those words carries a footnote: substituted by Notification FEMA 23(R)/(1)/2026-RB dated 22 September 2026, replacing "fifteen months" and "eighteen months".

Where people go wrong

Reading the EDF date as a collection date. The 30 days is a filing deadline. The money still has its own nine-month clock from the invoice. A firm can file every EDF on time and still be late on realisation.

Assuming only software exporters are affected. Under the 2015 framework SOFTEX covered software; most other service exporters filed nothing. Regulation 3 declares services generally, so a design agency, a consultant or a freelancer billing overseas becomes a declarant on 1 October. For them the authority is the AD bank, not STPI.

Planning on 15 months. The 15-month figure was in the Regulations as notified in January and in nearly every article since. It was substituted on 22 September. An October invoice in dollars is due for realisation by July 2027, not January 2028.

Carrying a September bill into the new rule. The 2026 Regulations contain no transitional provision for bills outstanding on 1 October; the supersession keeps things done before it under the old Regulations. My reading, with most commentators, is that the regime in force when you exported governs the bill for its whole life. For a foreign-currency bill of June to September the amendment makes the question almost academic: both regimes now give nine months. It still matters for a rupee-invoiced bill and a warehouse export. Put it to your AD bank in writing.

What to do

1. File SOFTEX as usual for software invoices raised up to 30 September 2026, and stop there.
2. From October invoices, diarise one EDF per month, due 30 days after that month ends; the first falls on 30 November 2026 for October invoices.
3. Re-date your realisation diary for every invoice from 1 October at nine months (twelve if invoiced or settled in rupees), whatever an earlier article or tool told you.
4. Ask your AD bank in writing how it wants the EDF submitted. RBI has not published the filing route.
5. For a rupee-invoiced or warehouse bill that straddles 1 October, get the bank's answer on which regime applies before you rely on the longer date.

The tool

I built a FEMA realisation-period resolver because the period had changed four times in eleven months and every guide quoted one number. I am not linking it today. The version live now names the EDF correctly and flags the 30-day filing rule, but it still gives 15 months (18 in rupees) for bills from 1 October, which is the figure RBI substituted on 22 September. It does not compute the EDF deadline, it files nothing, and until it is corrected it will overstate the period for new bills. I will link it here once it carries the amended Regulation 5.

Sources

1. RBI — Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification FEMA 23(R)/2026-RB, 13 January 2026, as amended up to 22 September 2026 (Regulations 3 and 5, and footnotes citing FEMA 23(R)/(1)/2026-RB) — https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13277&Mode=0
2. RBI — Notification FEMA 23(R)/(8)/2026-RB, 5 June 2026 (the 9-month reversion under the 2015 Regulations), via https://caalley.com/fema26/EGS050620261F93347664F94E4491D6F8762DFF8EF7.pdf
3. TaxGuru — RBI extends export proceeds realisation timeline (13 November 2025 amendment) — https://taxguru.in/rbi/rbi-extends-export-proceeds-realisation-timeline.html
4. LKS Attorneys — RBI releases FEMA 2026 export-import trade regulations — https://www.lkslaw.com/insights/articles/rbi-releases-fema-2026-export-import-trade-regulations-what-businesses-need-to-know
5. EY India — RBI issues EXIM guidelines (the Directions of 16 January 2026) — https://www.ey.com/en_in/technical/alerts-hub/2026/03/rbi-issues-exim-guidelines
6. Skydo — Export Declaration Form (filing route not yet published) — https://www.skydo.com/blog/export-declaration-form