In France it is: "engineer"-the-title specifically means having a degree from a state-certified engineering school, and when you get the degree the state inscribes you as an engineer in a national registry.
Whether it's software engineer or another domain is immaterial, the title "engineer" is heavily protected and making use of it without the degree is liable for pursuit the same way claiming to be a doctor and delivering medical advice when one is not: in the same way as with the Hippocrates oath, engineers are held to a high moral standard of ethics and integrity. The words "élite de la nation" often comes up - and often in derogatory ways from outsiders - but it is borne out from these requirements, that engineers are to be placed in position of great power and corresponding responsibility, meaning they have a duty to call the shots in high stakes situations in ways that go beyond technical knowledge and mastery but also factor in intellectual and moral values.
One can get a masters degree in computer science and/or software development though, which is the same "knowledge level" of studies (an engineering degree doubles as a masters degree), but that does not make one an engineer, which is a corps (in the same sense that e.g US Marines are a corps). This dates back to Napoleon and the creation of "classes préparatoires" and public (state-owned) engineer schools, heavily inspired by the military. Case in point Polytechnique is a military school (although the goal is not to produce armymen), and entering any of the three french military corps (the navy, the air force, and the "ground" army) as an officer goes through the same classe préparatoire process.
This design has been relaxed over time and for quite a time there are private engineering schools that don't require going through these first two prépa years, but they still require the state certification to legally produce engineers.