Fema Rbi Regulatory Reporting

FEMA & RBI Regulatory Reporting

Foreign investment into or out of India creates a reporting obligation that runs for as long as the investment exists, and it is the obligation most often missed — usually because it sits between the company secretary, the accountant and the banker, and nobody has clearly been given it.

The costs of missing it are real: late submission fees, compounding applications to the RBI, and a diligence finding that delays or reprices a transaction. We own this reporting end to end, from the entity’s first registration on the RBI portal to the annual returns nobody remembers are due.

What’s included

Inbound Investment

1. Entity Master Form registration and annual updation on the RBI FIRMS portal

2. FC-GPR — reporting the issue of shares to a non-resident, within 30 days of allotment

3. FC-TRS — reporting transfer of shares between resident and non-resident

4. LLP-I and LLP-II — foreign investment into and disinvestment from an LLP

5. CN and DRR forms for convertible notes and depository receipts as applicable

6. FLA return — the annual Foreign Liabilities and Assets return, due 15 July each year, which a surprising number of companies with any foreign shareholding have never filed

7. Advance remittance reporting and KYC coordination with the AD bank

8. Sectoral cap, entry route and pricing guideline checks before the transaction, not after

9. Valuation coordination for pricing compliance [[ valuation certificates are issued by registered valuers / merchant bankers ]]

10. Downstream investment reporting (Form DI)

Outbound Investment

1. ODI reporting for overseas direct investment, Form FC

2. APR — annual performance report for each overseas entity

3. Disinvestment and closure reporting

4. Structuring and jurisdiction input

Borrowings

1. ECB Form 83 / loan registration number

2. ECB-2 monthly returns

3. Trade credit reporting

Remediation

1. Late Submission Fee computation and payment

2. Compounding applications to the RBI — drafting, documentation and follow-through

3. FEMA health check across all entities in a group, with a written list of open items

Who This Is For

Any Indian company with a foreign shareholder, however small. Any Indian company with a subsidiary or JV abroad. Any company that has taken external commercial borrowing. Startups that have raised from foreign investors — this catches a lot of founders by surprise.

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Frequently Asked Questions?

We raised foreign money three years ago and never filed FC-GPR. What now?

It is fixable. There is a late submission fee mechanism and, for older or more serious lapses, a compounding route with the RBI. We quantify the exposure first so you know what you’re dealing with, then run the remediation.

We have foreign shareholders but no new investment this year. Do we still file anything?

Yes — the FLA return is due every year by 15 July for as long as foreign investment sits on the balance sheet, and the Entity Master needs annual updation.