There’s a lot of gray area in software development. Depending on a lot of variables, you MAY be “providing a service” to do custom work, or you MAY be “exporting intangible goods” (software).

So it’s a huge maybe. A lot of it depends on how the tariff rules are written and put into effect.

The rules can get VERY complex. The U.S. has a variety of offices related to different aspects of international trade. For example, the Office of the U.S Trade Representative reports directly to the president and is responsible for advising on trade. The International Trade Administration is (a bureau within the U.S. Department of Commerce) works to ensure American businesses have access the global markets without unfair foreign government business practices. And that doesn’t even get into the U.S. Department of State’s international interests, or private lobbyists such as the U.S. Chamber of Commerce.

There will be no easy answers. Even when rules come out, the various agencies will take weeks or months to figure out how to interpret and enact the rules. Sometimes, clear sounding things end up having a ton of nuance. If anyone offers you an easy answer, don’t listen to them.

(Source: I spent years working at the Department of Commerce.)