Expert opinion · Exports

P0802 or P0807: choosing the software purpose code now that SOFTEX has ended

Short answer. P0807 is for off-site software exports: software built in India and delivered to the client abroad electronically, including licences and subscriptions to your own product. P0802 is for software consultancy and implementation: advising on, configuring or implementing systems, including work done at the client's site. Since 1 October 2026 both are declared on the monthly EDF instead of SOFTEX, so the code describes the work but no longer decides the form.

For years the choice between the two software codes followed the SOFTEX form: what went on SOFTEX was an off-site export, P0807. SOFTEX is gone, so the question has to be answered from the work itself.

CA Prachi GoelChartered Accountant · FEMA, RBI reporting and cross-border tax 6 min read Updated
P0807Off-site software exports
  • Software built in India, delivered electronically
  • Licence fees and subscriptions to your own product
  • Was declared on SOFTEX before October 2026
P0802Software consultancy / implementation
  • Advice, configuration and implementation of systems
  • Work done at the client's site abroad
  • Development billed as consulting time, where the bank agrees
P0807 compared with P0802

Key points

  • P0807 is RBI's code for off-site software exports; P0802 for software consultancy and implementation.
  • SOFTEX ended on 1 October 2026: software exports are declared on the monthly EDF like other services.
  • For the EDF both codes count as software exports, due within 30 days of the month end.
  • Choose the code from what the invoice sells, match it to the SAC code, and use it consistently with your bank.
  • Maintenance of software already delivered is P0804; hosting and data processing are P0803.

What changed on 1 October 2026

Under the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, in force from 1 October 2026, the SOFTEX form is gone. Every export of services, software included, is declared on the Export Declaration Form: one EDF a month covering all the month's invoices, given to the AD bank through which the money comes in (STPI may take software exports, and SEZ units file with their SEZ authority), within 30 days from the end of the month. The operational guidelines are in A.P. (DIR Series) Circular No. 25 of 28 September 2026.

Other services may instead be declared on or before the day the payment arrives; software exports keep the 30-day monthly route. The proceeds are due within nine months of the invoice, twelve when invoiced in rupees.

The two codes

RBI's list names P0802 "software consultancy / implementation" and P0807 "off-site software exports". Before October 2026 the line between them was drawn by the SOFTEX form: software developed in India and transmitted abroad went on SOFTEX and was coded P0807, while consultancy and implementation outside SOFTEX, including work at the client's site, was P0802. With SOFTEX gone, ask what the invoice sells.

The workCodeWhy
Licence fees for software you own, delivered by downloadP0807Software made in India, delivered off-site
Subscriptions to your own SaaS product from customers abroadP0807Your software, used abroad over the internet
A fixed-price application built in India and handed over as codeP0807Development delivered from India; it was a SOFTEX export
Configuring and implementing an ERP for a client abroadP0802Implementation work on the client's systems
A consultant working at the client's office abroadP0802On-site consultancy, never an off-site export
Support and fixes to software already deliveredP0804Repair and maintenance of computers and software
Hosting, data processing or data entryP0803Database and data processing

Custom development: the borderline case

Development for a client billed by the hour or month sits between the two. It is built in India and delivered electronically, which points to P0807, and under SOFTEX it was usually declared as an off-site export. P0802 is also widely used for development under a services contract, and freelance developers often receive it that way. Either is defensible; what matters is that the code agrees with the contract and the invoice, and that you use the same one each month. When in doubt, ask your AD bank which it reports, before the first receipt.

Why the code still matters

The purpose code travels with the money. It appears on the FIRA, in the bank's reporting to RBI and on the IRM from which the eBRC is generated. It should sit easily with the SAC code on your invoice: 998314 (IT design and development) or 997331 (licensing the right to use software) for P0807, and the consultancy and implementation services for P0802. A code that does not fit the invoice draws questions from the bank, and correcting it later takes a letter.

The code does not change the tax or GST. Either way the receipt is an export of services, zero-rated for GST when its conditions are met, and your income for income tax. If the client's country withheld tax, keep its certificate for the credit.

Choosing it once, in FxLayer

FxLayer's purpose-code picker asks what kind of work was done and suggests the code with its alternative, the invoice maker maps the SAC code to the code, and the monthly EDF groups software exports separately so each goes to the right authority on time.

Questions

No, for invoices dated from 1 October 2026. Software exports are declared on the monthly EDF instead. SOFTEX forms already filed for earlier exports stay as they are.
For building or fixing software for a client, P0802 is commonly used, and P0807 also fits development delivered from India. Pick one with your bank and keep to it. Licences or subscriptions to your own product are P0807.
No. The EDF goes to the AD bank through which the money comes in. STPI may take the EDF for software exports, and SEZ units file with their SEZ authority.
Write to the bank with the invoice and the contract and ask it to correct the code it reported. It is easier to give the right code on the first receipt.

Sources

This article is general information on Indian foreign exchange and tax rules as they stood on the date shown. It is not legal or tax advice. Rules and limits change; confirm the current position with your AD bank, the relevant RBI Master Direction or your adviser before acting.

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