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Last updated: 2 October 2026
If your company has foreign shareholders, invests abroad or borrows from overseas lenders, FEMA sets strict reporting timelines. Expertvuw’s team maps your cross-border transactions, files RBI returns through your AD bank and the RBI portals, and fixes past gaps.
The Foreign Exchange Management Act, 1999 (FEMA) governs transactions between residents and non-residents. For companies, the main areas are foreign investment into India, overseas investment by Indian entities, external commercial borrowings (ECB), and exports and imports. Each has its own rules, forms and time limits, and most reporting runs through the company’s Authorised Dealer (AD) bank.
Foreign investment is reported on RBI’s FIRMS portal through the Single Master Form — for example FC-GPR within 30 days of allotting shares to a non-resident, and FC-TRS within 60 days of a transfer between a resident and a non-resident. Overseas investment is reported under the Overseas Investment Rules and Regulations, 2022, including the Annual Performance Report. ECB is governed by the FEMA (Borrowing and Lending) Regulations, which were substantially revised from 16 February 2026.
Every company with foreign investment or overseas investment also files the annual Foreign Liabilities and Assets (FLA) return. Delays can usually be regularised with a late submission fee within the time allowed; beyond that, compounding with RBI may be needed.
Basis: FEMA, 1999; FEM (Non-debt Instruments) Rules, 2019; Master Direction – Foreign Investment in India (as updated); Overseas Investment Rules, Regulations and Directions, 2022; FEMA (Borrowing and Lending) Regulations, 2018 as amended February 2026. Last updated: 27 September 2026.
Within 30 days of allotment of shares to a non-resident.
Within 60 days of transfer or receipt/remittance of funds, whichever is earlier; filed by the resident party.
Within 30 days where an Indian entity owned or controlled by non-residents makes a downstream investment.
Annually by 15 July on RBI's FLAIR portal (subject to RBI extensions).
By 31 December each year for each overseas entity.
Delayed filings can be regularised with a late submission fee within three years; after that, compounding applies.
FEMA issues are usually discovered during due diligence, fundraising or an RBI query.
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FEMA compliance connects with these services.
Reporting share allotments to foreign investors.
Reporting share transfers with non-residents.
Annual Foreign Liabilities and Assets return.
Regularising past FEMA contraventions.
List all cross-border transactions since incorporation.
Compare with filings on FIRMS and with the AD bank.
File pending forms with late submission fee where allowed.
Handle new transactions within the time limits.
File FLA and APR each year.
Prepare compounding where late fee is no longer available.
Some FEMA filings are event-based and some are annual.
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Reporting and following RBI rules for foreign investment into the company, overseas investment by it, foreign borrowings, and exports and imports.
Within 30 days from the date of allotment of shares to a non-resident, filed on RBI’s FIRMS portal.
Most delayed filings can be made with a late submission fee within three years. Beyond that, the contravention may need to be compounded with RBI.
Indian companies, LLPs and certain other entities that have received foreign direct investment or made overseas direct investment.
From 16 February 2026, RBI revised the ECB framework, including borrowing limits, removal of the all-in-cost ceiling and simpler ECB-2 reporting.
ACS – Director, Expertvuw Management Pvt Ltd
FEMA filings are prepared by Expertvuw’s team. Certificates required by the AD bank or RBI are issued by independent practising professionals, and representation before RBI or the Directorate of Enforcement is made by authorised professionals or advocates.