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Home / NBFC & Fintech / FEMA Compliance
RBI’s FEMA reporting net covers foreign investment coming in, overseas assets going out, and every foreign loan serviced in between — miss a filing window and what should have been a routine form turns into a compounding application. CS Chetna Shoor keeps your FEMA compliance current, before RBI has reason to look closer.
Any Indian company receiving foreign investment, any resident acquiring an interest abroad, and any entity servicing a foreign loan is subject to reporting obligations under FEMA, 1999, administered by RBI through its various regulations — the Non-Debt Instruments Rules, the Debt Instruments Regulations, the Overseas Investment Rules, and the Borrowing and Lending Regulations. These aren’t one-time approvals. FC-GPR is due within 30 days of share allotment, FC-TRS applies on every transfer between resident and non-resident, Annual Performance Reports track overseas investments for as long as they’re held, and the FLA Return is due every year by July 15 for any company carrying foreign investment on its books. Each filing runs on its own clock, and each carries its own late-filing exposure.
Miss enough of them and the fallback path becomes compounding — an admission of contravention and a penalty, rather than a routine filing closed on time. This page is for founders and finance teams with existing or upcoming foreign investment, overseas subsidiaries, or foreign borrowing who need the reporting calendar built and maintained, not rebuilt after RBI flags a gap. Chetna reviews your cap table, corporate structure, and transaction history, then sets up the filing cadence and standing documentation that keeps it current.
FC-GPR filing window from the date of share allotment to a non-resident
Annual FLA Return due date for companies with FDI or ODI on the balance sheet
Governing statutes underlying the reporting obligations
Late Submission Fee applies to delayed FC-GPR, FC-TRS, and ODI filings on a graded formula
Any resident entity with inbound FDI, outbound ODI, or outstanding ECBs is in scope
Updated periodically — most recently January 2025 (Foreign Investment) and 2025–26 (Borrowing & Lending, Compounding)
RBI rejects over 40% of NBFC applications on the first attempt. Here’s what actually causes it.
FC-GPR, FC-TRS, FLA, APR, and ECB-2 each run on separate clocks tied to different trigger events — a share allotment, a transfer, a financial year-end, a drawdown. Tracking them individually, across multiple transactions and years, is where gaps open up.
The LSF is calculated on the amount involved and the period of delay, and it grows the longer a filing sits unreported. What looks like a small oversight in year one can become a materially larger fee — or an outright compounding case — by the time it's caught.
RBI's review of a single delayed FC-GPR often surfaces every other unreported transaction in the same corporate structure. A gap discovered reactively rarely stays isolated to the filing that triggered the review.
Any allotment or transfer of shares, convertible instruments, or eligible securities to a non-resident under the FDI route requires FC-GPR or FC-TRS reporting, regardless of the investment size.
An Indian resident or company acquiring equity or debt abroad, or setting up a subsidiary or joint venture overseas, falls under the Overseas Investment Rules and requires Form FC filing plus annual APR compliance for as long as the investment is held.
Loans raised from foreign lenders by an eligible Indian borrower fall under the ECB framework, with its own registration and monthly reporting distinct from FDI or ODI reporting. See our ECB Compliance service.
We review your corporate structure, cap table, and transaction history to map every reportable event, filed and unfiled.
Cross-check RBI's filing records against your internal transaction log to flag missed or delayed reporting.
Build a standing compliance calendar covering FC-GPR/FC-TRS triggers, FLA due dates, ODI/APR cycles, and ECB reporting where applicable.
Where gaps exist, prepare late filings or route eligible cases to compounding.
Each transaction filed within its RBI window, with acknowledgment tracked and retained.
Recurring annual filings prepared and submitted ahead of the 15 July / prescribed deadlines.
Every future share allotment or transfer to a non-resident reported within its FC-GPR / FC-TRS window.
Annual FLA Return filed by 15 July, every year the company carries FDI or ODI on its books.
APR filed annually for each overseas subsidiary or joint venture, for as long as the investment is held.
ECB-2 reporting kept current for the life of any outstanding foreign borrowing.
CS Chetna Shoor’s team replies within 4 hours on WhatsApp.
It covers every reportable cross-border event tied to the company — FC-GPR and FC-TRS for share allotments and transfers, annual FLA Returns, ODI and APR filings for overseas investments, and ECB-2 reporting for foreign borrowings, all filed within RBI’s prescribed windows.
A delayed FC-GPR attracts a Late Submission Fee calculated on the amount involved and the period of delay. If the delay is significant or unreported for long enough, the matter may need to be resolved through RBI’s compounding process instead of a straightforward late filing.
Yes — any Indian company with foreign direct investment or overseas direct investment on its balance sheet as of the end of the financial year must file the FLA Return with RBI by 15 July, even if there was no fresh transaction during the year.
FDI reporting (FC-GPR/FC-TRS) covers equity and convertible instruments issued to non-residents, with no repayment obligation. ECB reporting covers foreign currency loans with a defined maturity and repayment schedule, and runs on a separate registration and reporting track under the Borrowing and Lending Regulations.
Qualified Company Secretary · ICSI Member · Founder, Expertvuw Management Pvt Ltd
Chetna has guided NBFC promoters through RBI’s COR process end to end, with particular focus on structuring the Net Owned Fund and business plan so the application survives first-round RBI scrutiny rather than coming back with a query.