Which RBI Purpose Code Applies to SaaS Subscription Revenue From Foreign Customers?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
- Published:
- Last modified:
Short answer
RBI's FETERS list has no code named SaaS. Exporters of subscription software compare P0807, off-site software exports, with P0802 for implementation work and P0803 for data processing. The invoice wording and your AD bank's view decide the code, so confirm it with the bank.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| SaaS companies and founders in India billing customers outside India for subscriptions | Regulation 18(2) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, read with the RBI FETERS purpose code list | Service EDF within 30 days from the end of the invoice month; realisation within 9 months (12 months if invoiced or settled in rupees) | Not applicable for the code itself. A wrong code can trigger bank queries and correction requests | 9 Oct 2026 |
What is the purpose code for SaaS subscription revenue?
RBI has not published a purpose code specific to SaaS. Exporters choose from the existing software lines in Group 08 of the FETERS list. Banks may accept different codes, so the safest step is to agree the code with the AD bank.
- Closest lines: P0807 is "Off-site Software Exports". P0802 is "Software consultancy/implementation (other than those covered in SOFTEX form)". P0803 is "Data base, data processing charges".
- No SaaS line: The RBI FETERS purpose code list does not mention SaaS or subscriptions by name. This page could not verify an official statement mapping SaaS to a single code.
- Bank view: Banks apply the list to the invoice. Ask your AD bank which code it accepts for subscription billing.
- Consistency: Use the same code across customers with the same plan so your records stay uniform.
The comparison below shows how each candidate code fits common SaaS billing.
Which purpose code fits which kind of SaaS revenue?
The billing model decides which code is closest. Subscription access to software developed in India compares with P0807. Paid onboarding or integration compares with P0802. Data-heavy processing services compare with P0803.
| SaaS revenue type | Candidate code | Official RBI description | Best for |
|---|---|---|---|
| Subscription access to software built in India | P0807 | "Off-site Software Exports" | Product SaaS with standard plans |
| Implementation, setup or customisation fees | P0802 | "Software consultancy/implementation (other than those covered in SOFTEX form)" | Enterprise SaaS with onboarding work |
| Data processing or hosting of customer data | P0803 | "Data base, data processing charges" | Data platforms and analytics tools |
| Support and maintenance contracts | P0804 | "Repair and maintenance of computer and software" | Plans sold as support |
| Services with no software line that fits | P1099 | "Other services not included elsewhere" | Revenue that fits no other line |
How do SaaS companies select a purpose code on a bank or payment dashboard?
SaaS companies select a purpose code by matching the invoice description to an RBI line, then entering that code where the AD bank or payment provider asks for the inward remittance purpose. Agree the choice with the bank before volume grows.
- Describe the product on the invoice as subscription access to software or the service provided, in plain words.
- Check the official description in the RBI list and match it to the wording on your invoice and contract.
- Give the same code and description to your AD bank or payment provider when you set up the receipt, and confirm it appears on the remittance advice.
- File the Export Declaration Form for services within 30 days of the end of the invoice month, as required by Regulation 3(2), unless a waiver applies. See EDF form for exports.
- Keep the invoice, contract, remittance advice and bank credit together, and ask your AD bank to correct a wrong code quickly using the steps in how to correct a purpose code.
Can a SaaS company bill many small customers under one code?
Many small subscriptions can share one code when the service is the same. The EDF rules in Regulation 3(2) allow a single EDF for some service exports to multiple recipients, so ask your AD bank how it wants this handled.
- Keep an invoice list for each customer.
- Ask the bank whether a monthly EDF applies.
What should a SaaS company do when the bank rejects its chosen code?
Ask the bank which code it will accept and why, then update the invoice template and payment settings to match.
What are the official purpose code descriptions SaaS companies should compare?
Compare the exact RBI wording before choosing. The table lists the Group 08 and Group 10 lines closest to SaaS billing.
| Code | Official RBI description | Group | Best for |
|---|---|---|---|
| P0802 | Software consultancy/implementation (other than those covered in SOFTEX form) | Telecommunication, Computer & Information Services | Implementation and consulting |
| P0803 | Data base, data processing charges | Telecommunication, Computer & Information Services | Data processing |
| P0807 | Off-site Software Exports | Telecommunication, Computer & Information Services | Exported software |
| P1099 | Other services not included elsewhere | Other Business Services | Revenue with no better line |
What happens when a SaaS company uses a purpose code the bank disagrees with?
If the bank disagrees with the code, it may raise a query, hold the credit until it is satisfied, or ask you to correct the record. The bank reports the code to RBI under FETERS.
- Queries: The bank may ask for the contract, invoice and plan description.
- Delays: A disputed code can slow the credit while the bank reviews the paperwork.
- Records: The remittance advice shows the code, so a mismatch shows up in your books.
Agree the code with the AD bank early and fix any wrong record with their help. See what happens if you use the wrong purpose code.
Which RBI rules support the purpose code choice for SaaS revenue?
The rules are the FETERS purpose code list, the circular that put it in force, and the 2026 export regulations that carry FETERS reporting forward.
| Circular or regulation | Clause | Date | Plain meaning | Best for |
|---|---|---|---|---|
| RBI FETERS purpose code list | Annex, receipts | Circular dated 29 February 2012 | Lists the purpose codes and descriptions banks use when reporting inward remittances | SaaS exporters with an AD bank |
| A.P. (DIR Series) Circular No. 84 | Paragraph 3 | 29 February 2012 | AD banks report foreign exchange transactions using this purpose code list | Banks reporting receipts |
| FEMA 23(R)/2026-RB | Regulation 18(2) | In force 1 October 2026, amended 22 September 2026 | FETERS reporting by AD banks continues under the 2026 export regulations | SaaS exporters after 1 October 2026 |
| FEMA 23(R)/2026-RB | Regulation 3(2) | In force 1 October 2026 | Service exporters file the EDF within 30 days of the end of the invoice month | Service exporters filing EDF |
| A.P. (DIR Series) Circular No. 20 | Paragraphs 4 and 7, Annex A | 16 January 2026 | Supersedes the earlier export Master Direction and the SOFTEX circulars from 1 October 2026 | Companies leaving SOFTEX |
What mistakes do SaaS companies make with purpose codes?
- Assuming a SaaS code: Believing RBI has a SaaS line. The list has none, so match the invoice to an existing line.
- Mixed codes: Using different codes for the same plan across customers. Keep one approach.
- No bank check: Never confirming the choice with the AD bank before large receipts.
- Missing EDF: Missing the 30 day service EDF under Regulation 3(2).
- Old SOFTEX habit: Treating SOFTEX as current. Circular No. 20 supersedes the SOFTEX circulars from 1 October 2026.
- GST confusion: Treating the code as proof of GST export status.
How did we verify this?
Every rule, deadline and form on this page is linked to its official source, checked on the dates below.
- RBI: Guidelines for Submission of Data, Foreign Exchange Transactions Electronic Reporting System (FETERS), purpose code list for receipts, Annex purpose codes, receipts (checked 9 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 84 dated February 29, 2012: Compilation of R-Returns, Reporting under FETERS, Paragraph 3: AD banks to report all foreign exchange transactions as per the revised purpose code list (checked 9 Oct 2026)
- RBI Notification No. FEMA 23(R)/2026-RB: Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (amended up to September 22, 2026), Regulation 1(2); 3(2) (EDF for services within 30 days from end of invoice month); 4(2) (EDPMS closure up to Rs 10 lakh); 5(1)(a) (nine months); 18(2) (FETERS reporting) (checked 9 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 20 dated January 16, 2026: Export and Import of Goods and Services, Paragraphs 4 and 7 and Annex A: earlier Master Direction and SOFTEX circulars superseded from October 01, 2026 (checked 9 Oct 2026)
- IGST Act, 2017, Section 2: Definitions (CBIC tax information portal), Section 2(6): definition of export of services (checked 9 Oct 2026)
- IGST Act, 2017, Section 16: Zero rated supply (CBIC tax information portal), Section 16(1)(a), 16(2) and 16(3) (checked 9 Oct 2026)
- GST Portal user manual: Furnishing of Letter of Undertaking (FORM GST RFD-11), Filing path Services > User Services > Furnish Letter of Undertaking (LUT) (checked 9 Oct 2026)
- Income Tax Department e-filing portal: Objective and scope of the New Act, Repeal of the 1961 Act on 01.04.2026 and the tax year concept (checked 9 Oct 2026)
Frequently asked questions
Does RBI have a purpose code specifically for SaaS?
No line in the RBI FETERS list is named SaaS or subscription. Exporters compare the existing software lines, mainly P0807 and P0802, with the invoice. Confirm the choice with your AD bank, since acceptance can vary. Rules can change, so check the linked official sources and your AD bank before acting.
Is P0807 the right code for SaaS subscriptions?
P0807 is described as off-site software exports and is a common candidate for software built in India and sold abroad. Whether it fits a given subscription depends on the invoice and the bank. Check with your AD bank before relying on it.
Can SaaS implementation fees use a different code from subscriptions?
Implementation and setup work can fit P0802, described as software consultancy or implementation. If one invoice mixes subscription and setup, separate the lines where possible, or ask the AD bank how to record the receipt. Rules can change, so check the linked official sources and your AD bank before acting.
Does a SaaS purpose code appear on the FIRA?
The code is normally recorded on the inward remittance advice or FIRA your bank or payment provider issues. Formats vary, so check with your AD bank, and keep the document with the invoice. Rules can change, so check the linked official sources and your AD bank before acting.
Is SaaS revenue an export of services for GST?
It can be, when all five conditions in section 2(6) of the IGST Act are met, including place of supply outside India. The purpose code does not decide this. Take professional advice on place of supply for your product. Rules can change, so check the linked official sources and your AD bank before acting.
Is SOFTEX needed for SaaS revenue?
SOFTEX circulars are superseded from 1 October 2026 by Circular No. 20, and the EDF applies to software exports. See the linked SOFTEX and EDF pages and confirm the process with your AD bank. Rules can change, so check the linked official sources and your AD bank before acting.