FEMA Reporting Forms and Deadlines
Every FEMA transaction ends in a form. Here is which one, who files it, and by when.
Almost every FEMA transaction ends in a form. A foreign investor's money arrives, and the Indian company reports the share allotment. An Indian company invests abroad, and the AD bank reports the remittance. Most reporting is filed by the customer but routed through, or verified by, the AD bank, which is why branch officers are expected to know which form goes with which transaction.
The forms are collected in RBI's Master Direction on reporting under FEMA. This page groups them by transaction type, with the deadlines RBI currently prescribes.
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Foreign Investment Into India: The Single Master Form
Inward investment is reported online on RBI's FIRMS portal through the Single Master Form (SMF), which holds nine returns. The earlier Advance Reporting Form (ARF) has been folded into FC-GPR.
FC-GPR
Reports
Issue of equity instruments by an Indian company to a non-resident
Deadline
30 days from the date of issue
FC-TRS
Reports
Transfer of equity instruments between a resident and a non-resident
Deadline
60 days from transfer or receipt/remittance of funds, whichever is earlier
LLP-I
Reports
Foreign investment in an LLP by way of capital contribution
Deadline
30 days
LLP-II
Reports
Disinvestment or transfer of capital contribution in an LLP
Deadline
60 days
CN
Reports
Convertible notes issued by a startup to a non-resident
Deadline
30 days from issue
ESOP
Reports
Employee stock options or sweat equity issued to non-residents
Deadline
30 days from issue
DRR
Reports
Issue or transfer of depository receipts
Deadline
30 days from close of issue
DI
Reports
Downstream investment by an Indian entity with foreign investment
Deadline
30 days from allotment
InVi
Reports
Investment vehicle units issued to non-residents
Deadline
30 days from issue of units
| Form | Reports | Deadline |
|---|---|---|
| FC-GPR | Issue of equity instruments by an Indian company to a non-resident | 30 days from the date of issue |
| FC-TRS | Transfer of equity instruments between a resident and a non-resident | 60 days from transfer or receipt/remittance of funds, whichever is earlier |
| LLP-I | Foreign investment in an LLP by way of capital contribution | 30 days |
| LLP-II | Disinvestment or transfer of capital contribution in an LLP | 60 days |
| CN | Convertible notes issued by a startup to a non-resident | 30 days from issue |
| ESOP | Employee stock options or sweat equity issued to non-residents | 30 days from issue |
| DRR | Issue or transfer of depository receipts | 30 days from close of issue |
| DI | Downstream investment by an Indian entity with foreign investment | 30 days from allotment |
| InVi | Investment vehicle units issued to non-residents | 30 days from issue of units |
Other Returns a Branch Will Meet
- FLA return
- Annual Return on Foreign Liabilities and Assets, filed on RBI's FLAIR portal by companies, LLPs and SEBI-registered AIFs that have received FDI or made investment abroad. Due by 15 July every year.
- Form ECB and ECB-2
- Form ECB is filed to obtain a Loan Registration Number (LRN) for an external commercial borrowing; Form ECB 2 reports drawdowns and debt servicing within 7 calendar days from the end of the month in which they happen, filed through the designated AD bank, which certifies and submits it to RBI.
- Form FC
- Reports overseas direct investment by an Indian entity, under the 2022 Overseas Investment framework.
- ODI Part II / APR
- The Annual Performance Report on each foreign entity in which an Indian entity holds ODI.
- Form OPI
- Reports overseas portfolio investment by Indian entities.
- EDF
- Export Declaration Form. Under the FEM (Export and Import of Goods and Services) Regulations 2026, in force from 1 October 2026, goods exporters file it at the time of export and services exporters within 30 days from the end of the month in which the invoice was raised.
- Form A2
- The application-cum-declaration a resident submits to the AD bank for an outward remittance; still referenced in the overseas investment directions.
Courseware Forms vs the 2026 Export Rules
Older courseware describes separate export declaration forms, including SOFTEX for software exports. From 1 October 2026 the new export and import regulations replaced RBI's export and import Master Directions and 167 circulars (96 on exports, 71 on imports), and they prescribe the EDF for both goods and services. Learn the courseware's names for the exam, but know the current position for the counter.
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Late Submission Fee: Paying for Delay Instead of Compounding
A late return need not go to compounding. RBI allows it to be regularised by paying a Late Submission Fee (LSF).
- 1
Identify the return type
Non-flow returns (such as the APR, FC-GPR Part B and FLA) attract a flat ₹7,500. Flow returns (FC-GPR, FC-TRS, ESOP, LLP, CN, DI, InVi, ODI Parts I and III, Form FC, ECB returns) attract a formula fee.
- 2
Compute the flow-return fee
₹7,500 plus 0.025% of the amount involved multiplied by the years of delay (counted to the nearest month), capped at 100% of the amount involved.
- 3
Check the window
LSF is available only for delays of up to 3 years from the due date. Beyond that, the contravention has to be compounded.
- 4
Pay within 30 days of the advice
Failing to file, or filing without paying LSF, leaves the person open to action under FEMA.
How CCFE Tests This
Expect matching questions: which form reports a share transfer (FC-TRS) versus a fresh issue (FC-GPR), the deadline for each, and who files the FLA return and by when. The trap is the 30 versus 60 day split: FC-GPR, CN, ESOP, DI and LLP-I are 30 days, while FC-TRS and LLP-II are 60. Another is assuming every late filing goes to compounding, when LSF covers delays of up to 3 years.
FAQs
What is the time limit for filing FC-GPR?expand_more
Within 30 days from the date the equity instruments are issued to the non-resident. It is filed on RBI's FIRMS portal as part of the Single Master Form.
Who files FC-TRS and what is the due date?expand_more
The resident transferor or transferee (or a non-resident holding on a non-repatriable basis), within 60 days of the transfer or of the receipt or remittance of funds, whichever is earlier.
What is the due date for the FLA return?expand_more
15 July every year. Indian companies, LLPs and SEBI-registered AIFs that have received FDI or made overseas investment file it on RBI's FLAIR portal.
What is the Late Submission Fee under FEMA?expand_more
A fee RBI accepts to regularise a delayed return without compounding: ₹7,500 for non-flow returns, and ₹7,500 plus 0.025% of the amount per year of delay for flow returns, capped at the amount involved. It applies to delays of up to 3 years.
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