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 work | Code | Why |
|---|---|---|
| Licence fees for software you own, delivered by download | P0807 | Software made in India, delivered off-site |
| Subscriptions to your own SaaS product from customers abroad | P0807 | Your software, used abroad over the internet |
| A fixed-price application built in India and handed over as code | P0807 | Development delivered from India; it was a SOFTEX export |
| Configuring and implementing an ERP for a client abroad | P0802 | Implementation work on the client's systems |
| A consultant working at the client's office abroad | P0802 | On-site consultancy, never an off-site export |
| Support and fixes to software already delivered | P0804 | Repair and maintenance of computers and software |
| Hosting, data processing or data entry | P0803 | Database 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
Sources
- RBI Notification No. FEMA 23(R)/2026-RB of 13 January 2026: Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026
- RBI Notification No. FEMA 23(R)/(1)/2026-RB of 22 September 2026: the amendment regulations
- RBI notifications, including the A.P. (DIR Series) circulars to AD banks
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.
