If your company receives foreign investment, borrows from overseas or invests outside India, you may need to submit reports under the Foreign Exchange Management Act, 1999 (FEMA). The filings that apply depend on your company’s activities and transactions.
Some deadlines fall on fixed annual dates. Others start when you issue shares, transfer ownership or complete another reportable transaction. This guide brings together the main requirements for FY 2026–27 and explains which reporting period each filing covers.
FEMA Reporting Updates to Know for FY 2026–27
The RBI updated several FEMA reporting requirements during 2026. Before using an existing compliance calendar, check the current instructions for each filing, including its form, deadline and submission route. The following updates are relevant to the reports covered in this guide.
● The RBI’s Master Direction on Reporting under FEMA now shows 1 October 2026 as its latest update. Referring only to the March 2026 version would miss later changes.
● For external commercial borrowings (ECBs), the amended regulations use Form ECB 1, Revised Form ECB 1 and Form ECB 2. Form ECB 2 reports receipts, debt servicing and other events that change outstanding borrowing, within seven calendar days after the relevant month-end.
● From 1 April 2026, the AD bank must forward complete, certified ECB returns to the RBI within seven calendar days of receiving them. Each delayed ECB 2 return is also treated separately when calculating the fixed component of the Late Submission Fee.
Important note: Your deadline for submitting a return to the bank and the bank’s deadline for forwarding it to the RBI are separate. Allow time for document checks and certification.
Annual FEMA Filings and Their Due Dates
Annual reporting depends on the investments your company holds and the reporting rules that apply. The FLA return covers foreign liabilities and assets, while the Annual Performance Report relates to overseas direct investment. Check the period covered by each report before adding its due date to your calendar.
FLA Return
The annual Foreign Liabilities and Assets (FLA) return is generally due by 15 July on the RBI’s FLAIR portal. It applies to entities meeting the RBI’s criteria for outstanding foreign direct investment (FDI) or overseas direct investment (ODI), including relevant holdings in the previous reporting year. A fresh investment during the year is not always necessary for the return to apply.
The return due on 15 July 2026 reports the position at 31 March 2026, with the required comparative information. The return covering the position at 31 March 2027 is due on 15 July 2027.
Revising an FLA Return
If your accounts are not audited by 15 July, file using provisional or unaudited figures. Once audited figures are ready, request permission through FLAIR to submit the revised return.
Annual Performance Report
If your company has made ODI, an Annual Performance Report (APR) is generally required for each relevant foreign entity by 31 December. Where that foreign entity’s accounting year ends on 31 December, the report is due by 31 December of the following year.
Exceptions include certain holdings below 10% without control and without other financial commitments, and foreign entities under liquidation. Overseas portfolio holdings do not automatically create the same APR obligation.
FEMA Filings Triggered by Transactions
Certain transactions, such as issuing shares to foreign investors or transferring shares, create immediate reporting deadlines. Record the transaction dates promptly, as deadlines may depend on the movement of funds and ownership changes.
An AD bank is a bank authorised to handle the relevant foreign exchange transactions. FIRMS is the RBI’s reporting platform used for the foreign-investment forms below.
| Filing | When it applies | Reporting deadline | Submission route |
|---|---|---|---|
| FC-GPR | Issue of equity instruments to a person resident outside India, where treated as FDI | Within 30 days of issue | FIRMS, through the AD bank workflow |
| FC-TRS | Covered transfers of equity instruments involving residents and non-residents | Within 60 days of transfer or receipt/remittance of funds, whichever is earlier | FIRMS, through the AD bank workflow |
| Form DI | Downstream investment treated as indirect foreign investment in the recipient Indian entity | Within 30 days of allotment of equity instruments | FIRMS, through the AD bank workflow |
| Form ECB 2 | Receipt of ECB proceeds, debt servicing or another event changing outstanding borrowing | Within seven calendar days after the end of the month in which the reportable event occurs | Designated AD Category I bank |
The equity-reporting requirements and ECB requirements have separate rules on applicability and supporting documents.
Reporting update: The separate Advance Remittance Form (ARF) was merged into the revised FC-GPR under the Single Master Form system. It should not appear as an additional current filing in your calendar. FIRMS and FLAIR are separate systems, so arrange the necessary access in advance. Overseas-investment and borrowing reports also involve the designated AD bank; these two portals do not cover every submission route in this guide.
Your FEMA Compliance Calendar for FY 2026–27
The calendar below shows the main reporting dates falling between April 2026 and March 2027, alongside suggested preparation tasks. It also includes the July 2027 FLA deadline because that return covers the financial year ending 31 March 2027.
Annual dates should be tracked alongside a separate record of transaction-based deadlines.
| Date or timing | Filing or task | What to check |
|---|---|---|
| April–June 2026 | Prepare FLA information | Reconcile investment records and financial data as at 31 March 2026; this is a suggested preparation period |
| 15 July 2026 | FLA return, where applicable | Reports the 31 March 2026 position and comparative information |
| Once audited figures are ready | Revise a provisional FLA return | Request permission through FLAIR before submitting the revised figures |
| 30 September 2026 | Annual Activity Certificate (AAC) | Branch and liaison offices reporting for the year ended 31 March 2026, under the applicable framework |
| 31 December 2026 | APR, where applicable | Confirm the foreign entity’s accounting year and any exemption |
| Within seven calendar days after a relevant month-end | Form ECB 2 | Track receipts, debt servicing and changes to outstanding borrowing |
| As reportable transactions occur | FC-GPR, FC-TRS and Form DI | Calculate each deadline from the prescribed trigger |
| 15 July 2027 | FLA return, where applicable | Reports the position at 31 March 2027, the end of FY 2026–27 |
The annual and transaction deadlines above come from the relevant RBI reporting frameworks.
Calendar note: A filing made during FY 2026–27 may relate to the previous year. Keep both the submission date and the period covered visible in your tracker. Check for any later RBI extension before filing.
Related Tax Deadlines
Tax filings sit outside FEMA, but you may wish to track them alongside RBI reporting. For FY 2025–26 / AY 2026–27, the standard deadlines where Section 92E applies are 31 October 2026 for Form 3CEB and 30 November 2026 for the income-tax return. Confirm any applicable extension separately; do not treat these as FEMA filings.
Which FEMA Filings Apply to Your Business?
Your legal structure and financial activities determine which reports you need to submit. An Indian subsidiary, a branch office and a liaison office do not follow identical requirements. Overseas investments and foreign borrowings can create additional obligations.
Use the following list to identify the requirements relevant to your business, then confirm their applicability with your AD bank.
● Indian company with foreign investment: Check the FLA requirement and any FC-GPR or FC-TRS filings triggered by transactions. Foreign ownership does not make every form an annual obligation.
● Company making downstream investments: Check whether the investment is treated as indirect foreign investment before applying Form DI reporting.
● Branch or liaison office: Check the AAC requirement. For a 31 March year-end, the applicable framework provides for submission by 30 September with audited financial statements. This is distinct from a subsidiary’s reporting. [8]
● Company with ODI: Check APR and other overseas-investment reporting requirements, including exemptions and the foreign entity’s accounting year.
● Company with ECB: Track initial loan reporting, relevant changes and Form ECB 2 submissions through the designated AD bank.
What Happens If You Miss a FEMA Filing Deadline?
Some reporting delays can be regularised through the RBI’s Late Submission Fee (LSF) mechanism. The amount depends on the filing and, for certain transaction reports, the amount involved and length of delay. Other contraventions may require a different process.
Identify the missed requirement first, then confirm the available route with your AD bank.
Late Submission Fee
Under the RBI’s applicable fee matrix, a delayed FLA return carries an LSF of ₹7,500 per return. For transaction filings such as FC-GPR, the formula is ₹7,500 + (0.025% × A × n), where A is the reportable amount and n is the delay in years, calculated using the prescribed rounding rules. The calculated fee is subject to the applicable cap.
The LSF option is generally available up to three years from the reporting due date, subject to the relevant framework. The March 2026 circular changes how delayed ECB returns are treated, so use the current instructions for those forms.
Compounding and Other Consequences
If LSF is unavailable or the issue goes beyond delayed reporting, confirm the appropriate regularisation process. Compounding under FEMA is an application-based process for eligible, admitted contraventions; it is not an automatic outcome for every default. RBI directions provide for a compounding order within 180 days of receiving a complete application.
Final Thoughts
Build your FEMA calendar around the filings that apply to your business. Track annual reporting dates, record transaction dates as they occur and confirm the correct submission route for each report.
For FY 2026–27, keep the reporting period clearly labelled and use current RBI instructions when calculating deadlines. Assign responsibility within your team and allow time for your AD bank to review the required documents.
FAQ'S
The standard deadline is 15 July. The July 2026 return reports the position at 31 March 2026, while the July 2027 return covers 31 March 2027. Comparative information is also required.
FC-GPR is due within 30 days of issuing equity instruments where the issue is treated as FDI. For covered transfers, FC-TRS is due within 60 days of transfer or receipt/remittance of funds, whichever is earlier.
FC-GPR, FC-TRS and Form DI use FIRMS. The FLA return uses FLAIR. Borrowing and overseas-investment reports follow their applicable submission routes through the designated AD bank.
Yes. The 2026 changes include updated ECB forms, reporting triggers, timelines and late-fee treatment. Do not assume that every requirement is unchanged because familiar equity-reporting deadlines continue.
Where the LSF mechanism is available, the applicable fee is ₹7,500 per delayed return. Follow the RBI’s process for late submission and contact the relevant regional office or your AD bank for guidance.
