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FEMA & RBI

GST-compliant on your software exports? RBI still wants its own filing on every one

Registering for GST and invoicing under a Letter of Undertaking covers the tax side of an export. It says nothing about the separate declaration your bank needs to match the payment to the invoice, and missing it surfaces as a stuck refund, not a GST notice.

You run a dev shop or an IT/ITES export business, properly GST-registered, invoicing overseas clients under a Letter of Undertaking so the export is zero-rated. Payments land by international wire, and everything looks in order. What often isn't in order is a separate, FEMA-side declaration that has to be filed for every foreign-currency export so RBI can match the money to the invoice, historically called SOFTEX, and it's not something GST registration or an LUT ever covers.
Last reviewed: 5 September 20265 min readReviewed by Preetesh Maloo, CA

The short answer

Being GST-registered and filing under an LUT covers the tax side of a software or IT-ITES export. It doesn't cover the separate declaration your bank needs for every foreign-currency export, so RBI can match the payment to the invoice. Until 30 September 2026, that's the SOFTEX form, usually certified through STPI. From 1 October 2026, SOFTEX is replaced by a single monthly Export Declaration Form (EDF) covering all your exports for the month, and your own bank can certify it directly, no STPI queue needed. Skip either one, and the practical consequence lands where it hurts: the bank can't generate the certificate your export needs, which stalls your GST refund and leaves the remittance sitting unresolved.

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GST compliance and this filing are two different systems answering two different questions

An LUT and GST registration answer the tax question: is this export correctly zero-rated. The export declaration answers a completely separate question RBI cares about: does the foreign-currency payment that landed in your account actually match a real, declared export invoice. A business can have flawless GST compliance and still have never filed a single one of these declarations, because nothing in the GST process checks for it, and nothing prompts a founder to look for a second filing once the first one feels done.

What changes on 1 October 2026

Up to 30 September 2026, software and IT/ITES exporters file SOFTEX for each export, typically certified through STPI, a process with its own queue and paperwork. From 1 October 2026, SOFTEX is retired: a single, unified Export Declaration Form (EDF) covers all of a business's exports, goods and services and software alike, filed once a month rather than per invoice, due within 30 days of the month's end. The other real change is who can certify it. STPI's near-monopoly on certification ends; your own AD bank can now certify the declaration directly, which for most software exporters turns what used to be a separate STPI process into something handled as part of ordinary banking.

What goes wrong without a CA

The recurring pattern: GST and the LUT were sorted correctly at setup, invoices go out, payments come in, and nobody separately arranged the export declaration because it doesn't look like a GST question at all, it looks like a banking formality. It surfaces later, usually when a GST refund claim stalls because the bank can't produce the realisation certificate the refund depends on, or when the bank flags a growing pile of unmatched inward remittances. Reconciling a backlog of past exports against past payments after the fact is real work; filing each one as it happens isn't.

What's involved

What the CA actually does

  1. 1

    We build the export declaration into your regular filing routine

    We set up SOFTEX, or the monthly EDF once it takes over from 1 October 2026, as a routine part of your export cycle alongside GST, not a separate thing that only gets remembered when something stalls.

  2. 2

    We reconcile a backlog if filings were missed

    Where past exports were never declared, we match them against the actual remittances received so your bank can generate the realisation certificate and release any GST refund stuck behind it.

  3. 3

    We manage the October transition for you

    We move your filing from SOFTEX to the new monthly EDF and get your AD bank set up to certify it directly, so the cutover doesn't create a gap in your export records.

What to have ready

Documents you'll typically need

  • Export invoices raised to your foreign clients
  • Foreign inward remittance advices or FIRC from your bank
  • Any SOFTEX filings already made, or confirmation that none have been
  • Your AD bank's export-certification contact or process

References on this page

  • FEMA export-reporting framework: every foreign-currency export of software or IT-enabled services needs its own declaration to RBI through the exporter's bank, separate from and in addition to GST registration or an LUT
  • SOFTEX form, in force until 30 September 2026: filed per export, historically certified by STPI or the relevant SEZ authority
  • RBI Notification FEMA 23(R)/2026-RB (13 January 2026): replaces SOFTEX with a single, unified Export Declaration Form (EDF) covering all exports of goods, services and software, effective 1 October 2026, filed monthly (one EDF per calendar month) within 30 days of month-end
  • From 1 October 2026, Authorised Dealer (AD) banks are recognised as a 'Specified Authority' alongside STPI and SEZ authorities, so software and IT/ITES exporters can get the declaration certified directly by their own bank
  • Practical consequence of a missing declaration: the bank cannot generate the export's realisation certificate, stalling the GST refund tied to that export and leaving the remittance unresolved in RBI's monitoring system; non-filing is itself a FEMA contravention under Section 13

Frequently asked questions

Common questions

No. That covers the tax side. A separate declaration to RBI, SOFTEX today, the EDF from October 2026, is needed for every foreign-currency export so the bank can match the payment to the invoice. Missing it blocks the bank's realisation certificate, not your GST return.

The bank can't generate the export's realisation certificate, which stalls any GST refund tied to that export and leaves the remittance unresolved in RBI's system. It's also its own FEMA contravention, so the fix is to file it retroactively, not to leave it as is.

Not from 1 October 2026 onward, your AD bank can certify the declaration directly. Before that date, STPI or your SEZ authority typically certifies it.

Every export, regardless of value. A small-invoice exemption existed years ago but was withdrawn, and the new EDF regime carries no minimum either.

Exporting software or IT services and not sure your RBI filing is current?

Tell us how your exports and payments are set up. A practising CA will confirm whether SOFTEX or the new EDF is owed, clear any backlog, and get your bank filing running alongside GST, on a free call, no obligation.

No card, no obligation. All certification and filing work is handled by ICAI-registered practising Chartered Accountants.