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.