Reporting timelines
| Form | Trigger | Due |
|---|---|---|
| FC-GPR | Issue of equity instruments to a person resident outside India | 30 days from issue |
| FC-TRS | Transfer between resident and non-resident | 60 days from transfer or receipt/remittance of funds, whichever is earlier |
| ESOP, InVi, CN, DRR | Issue (CN: issue or transfer; DRR: close of issue) | 30 days |
| DI | Downstream investment by an entity with foreign investment | 30 days |
| LLP(I) / LLP(II) | Receipt of consideration / receipt of funds on disinvestment | 30 days / 60 days |
| FLA | Foreign investment received or made, in the year | 15 July each year |
| Form ECB 1 | Proposed ECB | LRN before the first drawdown |
| Form ECB 2 | Drawdown or debt servicing | 7 calendar days from the end of that month |
| Form FC | Overseas direct investment | At the time of investment; restructuring and disinvestment within 30 days |
| APR | Each overseas entity | 31 December each year |
| Form OPI | Overseas portfolio investment | 60 days from the end of each half-year |
The Advance Reporting Form (ARF) is no longer filed separately. It was absorbed into the Single Master Form on FIRMS in September 2018, and the 2019 reporting regulations do not require it. Shares must still be issued within 60 days of receiving the money, or the money refunded within 15 days after that.
ECB 2 is now event-based
From 16 February 2026, under the amended Borrowing and Lending Regulations (Notification FEMA 3(R)(5)/2026-RB of 9 February 2026), Form ECB 2 is filed only for a month in which there is a drawdown or debt servicing. It is due within 7 calendar days from the end of that month, not the earlier 7 working days. From 1 April 2026 (A.P. (DIR Series) Circular 25 of 30 March 2026), Form ECB 1 is treated as a return without flows for LSF, and each late ECB 2 under an LRN counts as a separate case.
How the late submission fee works
LSF = ₹7,500 + (0.025% × A × n). A is the amount involved in the late filing. n is the delay in years, rounded up to the next whole month and stated to two decimals. Returns without flows pay a flat ₹7,500. The fee cannot exceed A and is rounded up to the nearest ₹100. Example: an FC-GPR for ₹5 crore filed 2 months and 5 days late counts as 3 months, so n = 0.25. ₹7,500 + 0.025% × 5,00,00,000 × 0.25 = ₹10,625, which rounds up to ₹10,700. You can use LSF only within three years of the due date. After that, you need compounding. Pay within 30 days of the advice, or the advice lapses.
Common questions
Is ARF still required before FC-GPR?
No. The Advance Reporting Form was absorbed into the FIRMS Single Master Form in 2018. Under the 2019 reporting regulations the company reports the issue in FC-GPR within 30 days of allotment. It does not file separately when the money arrives. Allot within 60 days of receipt or refund.
Do I file Form ECB 2 every month?
Not since 16 February 2026. Form ECB 2 is filed only for a month with a drawdown or debt servicing, within 7 calendar days from the end of that month. Months with no activity need no return. Four quarters without returns can get a borrower marked untraceable.
Is the LSF a penalty?
No. LSF is a fee to regularise a reporting delay without compounding. It applies only to the reporting delay. Any other contravention, such as a late allotment or a pricing breach, still needs compounding.
Which day counts as the filing date?
The date the form is submitted on FIRMS or to the AD bank in a complete form. A form returned for correction may not stop the clock. Keep the acknowledgement.