ACA AIR XML Generation - is SoftwareId a required field?

So in the manifest file for ACA AIR XML there is a field called SoftwareId. I know what this is, but do you HAVE to have this field? If your an Issuer and your creating your own XML and not using any kind of software do you really need to turn your process into its own "software", apply for a software developer TCC and add it on all of your XML manifests?

TL;DR; Yes, you need the softwareID and it has to go through an arduous process that takes a couple of weeks to move to production.

For those who are wondering. The sad truth is that if you are going to submit electronically then YES someone has to get a softwareID. The worst part is that once you put a software package on your application you have to follow the following steps before you can move any of your TCC codes to production:

1. submit all the test case scenarios (How to Submit and What to Submit)for that softwareID (different scenarios depending on if your submitting B or C files) Use your software ID and your software package TCC for these even though later you will be using your transmitter TCC.
2. when they are accepted you need to call the IRS (1-866-937-4130 1 for English and then 2 for person then on hold for hours) and get them to then have someone look over them line by line. They will give you a case number and get back to you in a few business days by email or phone. (your preference)
3. Once they get back to you A) if you passed then it will take 2 days to get your tcc codes moved from testing to production B) if you failed you have to resubmit the ones you messed up. (at this point you can usually just email back the person who told you you failed with the updated receiptID's)

Its a long and arduous process and if you have not started it yet you will NOT meet the deadline. Good luck to the rest of us...because thats only where the troubles START.