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CA India
Swati K & Co. Chartered Accountants ICAI FRN 021392S

STPI / SEZ Monthly Compliance

STPI and SEZ units enjoy export-led tax and procedural benefits — and a parallel monthly / quarterly / annual reporting calendar that’s easy to lose track of. MPR, SERF, QPR, APR, SOFTEX, NFE certification — done right, you keep the benefits; done late, you face deactivation.

What’s covered

The STPI / SEZ filing set

For STPI units:

  • MPR (Monthly Progress Report) — exports, imports, manpower, infrastructure.
  • SERF (Software Export Report Form) — software / IT / ITES export compliance.
  • SOFTEX — declaration via SEZ / STPI portal for software exports.
  • QPR (Quarterly Progress Report).
  • APR (Annual Performance Report) by 30 September.
  • NFE Compliance Certificate — positive Net Foreign Exchange earnings, certified annually.
  • Bond / LUT renewal.

For SEZ units, the same set with two additions: DSPF (DTA Services Procurement Form, added 2025) and Customs Shipping Bill per consignment.

Who needs this

Units that must file

Every STPI-registered unit and SEZ-registered unit, regardless of size. Compliance starts from the first month of operations. Missing reports for two consecutive cycles can trigger STPI / Development Commissioner notices and risk de-bonding.

Statutory framework

Policy, Acts, rules and FEMA references

The governing layer is:

  • Foreign Trade Policy chapters on STPI and SEZ schemes.
  • SEZ Act 2005 and SEZ Rules 2006.
  • STPI Guidelines notified by the Ministry of Electronics and IT.
  • FEMA Notification 23(R)/2015 on export realisation — revised in November 2025 from 9 to 15 months.
  • RBI Master Direction on Export of Goods and Services.
Our approach

How we run STPI / SEZ compliance

  • Compliance calendar set up — due-date map for MPR, SERF, QPR, APR, SOFTEX, bond renewal, NFE certificate.
  • Monthly data extraction from accounting system (sales, exports, manpower count).
  • SOFTEX form — one per export invoice, filed within 30 days of last invoice of the month.
  • MPR / SERF by 10th of following month.
  • QPR by 10th of month following quarter-end.
  • APR by 30 September annually.
  • NFE certification by an auditor, calculated on a 5-year cumulative block.
  • FEMA realisation tracking — 15-month outer limit per export invoice; AD-bank coordination on overdue receivables.
Documents we’ll ask for

What you’ll need to share

  • STPI / SEZ approval letter, LoP, LoA.
  • Monthly export invoices and corresponding FIRCs / BRCs.
  • Manpower register for the period.
  • Bank statements / AD bank confirmations.
  • Software export declarations (system-generated).
  • Capital goods import documents (for capital goods bond accounting).
  • Client / customer master with country and contract value.
Timeline & fees

How we charge

Monthly retainer covers MPR, SERF and SOFTEX. Quarterly add-on for QPR. Annual add-on for APR + NFE + bond renewal. Fixed-fee per unit, with discount for multi-unit clients. Custom add-on for adverse-event responses (notices, audit visits).

FAQ

Common questions on STPI / SEZ compliance

What’s the impact of the November 2025 FEMA amendment?

Export realisation timeline is now 15 months instead of 9. We re-baselined the receivables register for every STPI / SEZ client. Older invoices that were near the 9-month boundary are now within the 15-month buffer.

Is SOFTEX needed if the export invoice is paid promptly?

Yes. SOFTEX is a statutory declaration to RBI / STPI / Development Commissioner. Payment timing doesn’t change the obligation. Missed SOFTEX cannot be back-filed beyond a window.

What is NFE and why does it matter?

Net Foreign Exchange earnings — the positive difference between forex earned (export receipts) and forex spent (imports of goods / services / royalty payments). Must be cumulatively positive over a 5-year block. Negative NFE can lead to de-bonding.

Can our STPI unit also be a regular GSTIN tax-payer?

Yes. STPI status is for procedural / FEMA benefits. The unit still has GSTIN, files GSTR-1 / 3B / 9 / 9C and pays IGST on zero-rated supplies (or claims refund under LUT). The two regimes co-exist.

Ready when you are

Talk to a partner.

A 30-minute call with a partner — no deck, no follow-up email blasts. Just a read on whether we’re the right team to handle your STPI / SEZ monthly compliance.