Every Indian company exporting software or IT-enabled services carries an obligation most engineers have never heard of and most founders regard as the accountant's problem. Export declarations must be filed, and export proceeds must be realised within a stated window, or the tax treatment of invoices you have already booked as zero-rated changes. Two significant things have happened to that regime, and one of them takes effect in six weeks.
The first is the realisation window. Under the Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025, dated 14 November 2025, the period to realise export proceeds extended from nine months to fifteen months from the date of export. The window for completing an export after receiving advance payment extended from one year to three. For firms doing milestone-based work with long payment cycles — which describes most services exporters — that is a material easing of a constraint that used to convert ordinary commercial delay into a tax problem.
The second is the filing mechanism, and this is the one to act on. The framework notified as FEMA 23(R)/2026-RB, gazetted on 13 January 2026, consolidates export declaration into a single Export Declaration Form covering goods, services and software, with effect from 1 October 2026. Under it, service and software exports move to a consolidated monthly filing rather than transaction-level declarations, with authorised dealer banks certifying rather than STPI or SEZ authorities, and a simplified self-declaration closure route for entries at or below ten lakh rupees.
If that is right, it is a substantial simplification of a process that has been a genuine irritant. The old route required certification through STPI or the SEZ authority, which could take a month or two and sat outside your control. Moving certification to the bank you already deal with removes an intermediary and a queue. It also moves the relationship that matters: your authorised dealer bank becomes the party whose process you need to understand.
Because the change is imminent and the guidance in circulation is not yet uniform, the sensible action is not to redesign anything on the strength of a blog post — including this one. It is to ask your authorised dealer bank directly, before October, what they will require from you and in what format. Banks are preparing for this and will tell you. Ask specifically about outstanding EDPMS entries, because unclosed old entries are the thing most likely to cause friction during a transition, and clearing them is easier now than under a new process.
For anyone building accounting or billing software for Indian exporters, this is a product requirement rather than a client's paperwork. Your system should hold, per invoice, the export date, the realisation due date computed on the current window, the currency and settlement reference, and the declaration status — with visibility of anything approaching its deadline. That view is what turns a compliance obligation into an operational one, and it is exactly what most Indian exporters currently maintain in a spreadsheet that nobody looks at until year end.
