FEMA Reporting Requirements refer to the compliance framework under the Foreign Exchange Management Act, 1999, prescribed by the RBI through its Master Directions. They mandate timely reporting of foreign exchange transactions, including foreign direct investment (FDI), overseas direct investment (ODI), external commercial borrowings (ECB), liberalised remittance scheme (LRS), exports, imports, and non-resident accounts. Entities such as Authorised Dealer banks, companies, LLPs, and individuals must file specific forms and returns through RBI systems like FIRMS, FETERS, CIMS, and XBRL. These requirements ensure transparency, accurate monitoring of cross-border flows, and adherence to India's foreign exchange regulations.
Table of Contents
- Reporting Relating to Money Changing Activity
- Reporting Relating to Money Transfer Service Scheme (MTSS)
- Reporting Requirements Under Rupee Drawing Arrangements (RDA)
- Reporting Under LRS
- Reporting by BO/ (LO) / (PO) of Foreign Companies
- Reporting Under Foreign Direct Investment Norms
- Reporting Under Foreign Portfolio Investment
- Reporting of Investment by NRI
- Reporting of Downstream Investment
- Reporting of Investment by Foreign Venture Capital Investor (FVCI)
- Reporting of Investment by Non-Residents in Investment Vehicles
- Reporting of External Commercial Borrowings
- Reporting of External Commercial Borrowings
- Reporting of Overseas Direct Investment
- Reporting relating to Immovable property
- Reporting of Exports
- Reporting of Imports
The provision relating to reporting under FEMA is governed by RBI’s Master Direction – Reporting under FEMA, 1999 (FED Master Direction No. 18/2015-16), updated from time to time. This direction establishes a comprehensive reporting framework for all foreign exchange transactions. The reporting framework requires various entities, including Authorised Dealer banks, companies, LLPs, and individuals, to report inflow and outflow of foreign exchange in specific forms and returns. The reporting ensures transparency and enables the effective monitoring of foreign currency inflows and outflows across diverse financial activities. This article provides a consolidated overview of the reporting requirements under the Foreign Exchange Management Act (FEMA), 1999. The information is presented in a tabular format for easy reference.
1. Reporting Relating to Money Changing Activity
Authorised Money Changers (AMCs), also known as Full-Fledged Money Changers (FFMCs), are authorised by the RBI under Section 10 of FEMA, 1999. Along with AD Category I and II Banks, they widen access to foreign exchange facilities for residents and tourists. FFMCs can purchase foreign exchange from residents and non-residents and sell it for approved purposes. They may also appoint franchisees to purchase foreign currency. The prescribed return/forms for Authorised Money Changers (AMCs) are as follows:
| S. No. | Particulars | Form / Register / Statement |
| (a) | Applications | Application Form for FFMC Licence |
| (b) | Franchisee Related | Franchisee Information Form (RMC-F) |
| (c) | Registers to be Maintained | FLM 1 – Daily Summary (Currency Notes/Coins) |
| FLM 2 – Daily Summary (Travellers’ Cheques) | ||
| FLM 3 – Register of Purchases from Public | ||
| FLM 4 – Register of Purchases from ADs/AMCs | ||
| FLM 5 – Register of Sales to Public | ||
| FLM 6 – Register of Sales to ADs/FFMCs/Overseas Banks | ||
| FLM 7 – Register of Surrendered Travellers’ Cheques | ||
| FLM 8 – Monthly Summary statement of purchases and sales | ||
| (d) | Quarterly Statement | Foreign Currency Account out of Export Proceeds of Foreign Currency Notes/ encashed Travellers’ Cheques |
| (e) | Annual Statement | Foreign Currency Written Off during a financial year |
| (f) | Director Information | Proforma – Information on New/Change of Directors of the FFMC / non-bank AD Category – II |
2. Reporting Relating to Money Transfer Service Scheme (MTSS)
MTSS allows only inward personal remittances (like family maintenance or remittances to foreign tourists) through tie-ups between overseas money transfer companies (Overseas Principals) and Indian Agents. No outward remittance is allowed. Both remitters and beneficiaries must be individuals. Indian Agents can disburse funds, but cannot remit them back to Overseas Principals. Reporting / Returns under MTSS are as follows:
| S. No. | Name of Report/Returns | Format / Annexure | Frequency | Timeline | Submission Mode / Office |
| (a) | List of Sub Agents | Annex XV | Quarterly | Within 15 days of quarter-end | RBI FED Regional Office (updated list) |
| (b) | List of Additional Locations | – | Quarterly | Within 15 days of quarter-end | Concerned FED Regional Office |
| (c) | Quarterly Statement of Remittances | Annex XVI | Quarterly | Within 15 days of quarter-end | Through CIMS (NIL report if no remittance) |
| (d) | Half-yearly Statement of Collateral | Annex XVII | Half-Yearly (June & December) | Within 15 days from the reporting date | Concerned FED Regional Office (Indian Agents who are non-bank Authorised Category- II / FFMC shall submit the same in the APConnect application within the specified timeline) |
3. Reporting Requirements Under Rupee Drawing Arrangements (RDA)
Under the Rupee Drawing Arrangements (RDAs), cross-border inward remittances are received in India through Exchange Houses situated in Gulf countries, Hong Kong, Singapore, Malaysia (for Malaysia only under Speed Remittance Procedure) and all other countries which are FATF compliant (for all other countries which are FATF compliant only under Speed Remittance Procedure. The Reporting / Returns under RDA are as follows:
| S. No. | Report/Statements | Details / Purpose | Periodicity |
| (a) | Application (Annexe XVIII) | One-time application by AD Cat-I banks for opening/maintaining Rupee vostro accounts of those non-resident Exchange Houses. | One-time |
| (b) | Statement A (Annexe XIX) | Exchange House-wise details of Rupee/ foreign currency Vostro account operations. | Monthly |
| (c) | Statement B (Annexe XX) | Consolidated statement on Rupee/ foreign currency Vostro accounts to be closed/under closure. | Half-yearly |
| (d) | Statement C (Annexe XXI) | Details of overseas accounts of Exchange Houses under DDA/Non-DDA. | Monthly |
| (e) | Statement D (Annexe XXII) | Information on foreign currency Vostro account operations. | Monthly |
| (f) | Statement E (Annexe XXIII) | Remittances received; to be filed via CIMS (NIL report if no data). | Quarterly (before the 15th of the succeeding month) |
| (g) | Annual Review Note | To the RBI covering Exchange Houses’ creditworthiness, compliance, financials, risks, turnover, and Vostro account operations. | Annually (by 30th June) |
4. Reporting Under LRS
Resident individuals can remit up to USD 250,000 per year under LRS/FEMA. AD Category-I banks must report transaction-wise LRS data daily through the Centralised Information Management System (CIMS) and also in FETERS under relevant purpose codes. Banks must ensure the data in FETERS and CIMS is properly reconciled. The Reporting / Returns under LRS are as follows:
(a) Daily Return (CIMS): AD Category-I banks must report transaction-wise LRS data on a T+1 basis via the Centralised Information Management System (CIMS). ‘Nil’ report must be submitted if there are no transactions.
(b) FETERS Reporting: LRS transactions must also be reported in the Foreign Exchange Transactions Electronic Reporting System (FETERS) under the relevant purpose codes (e.g., travel, medical, studies, property purchase, maintenance of relatives).
(c) Data Reconciliation: AD banks must ensure LRS data reported in FETERS matches the data reported in CIMS.
5. Reporting by BO/ (LO) / (PO) of Foreign Companies
Foreign companies seeking to establish BO/LO/PO in India must comply with FEMA guidelines and reporting requirements through the AD Category-I banks.
The Reports/ Returns are as follows:
| Reports/Certificates/List | Details | Periodicity / Timeline | To be reported by | Reporting Authority | ||
| (a) Annual Activity Certificate (AAC) – Annexe I | Submission of AAC along with audited financial statements, including the receipt and payment account.
| On or before 30th September of every year, or within six months from the balance sheet date, if accounts are finalised with reference to a date other than 31st March | In case of Sole BO/LO: Office itself;
Multiple BOs/LOs: Nodal office | Designated AD Category-I bank and Director General of Income Tax (International Taxation), New Delhi | ||
| AAC from a Chartered Accountant
| Certification of project status, audited accounts, and conformity with general/specific RBI permissions. | Same as above | Project Office / Chartered Accountant | Designated AD Category-I bank | ||
| (b) Monthly Consolidated List – Annexe II | AD Category-I banks to report all BOs/LOs/POs opened or closed during the month. | By the 5th of the succeeding month. | AD Cat-I Bank | General Manager, RBI – Central Office Cell. Foreign Exchange Department, Sansad Marg, New Delhi-110 001 | ||
| (c) Annual Report to State Police – Annexe III | Applicable for entities from Bangladesh, Sri Lanka, Afghanistan, Iran, China, Hong Kong, Macau, and Pakistan. – Report to be filed within five working days of the office becoming functional. – A separate report must be filed for each office in different states. | Within five working days of the office becoming functional. | Entities setting up BO/LO/PO in India | Director General of Police (DGP) of the respective state. | ||
6. Reporting Under Foreign Direct Investment Norms
Foreign investments in India are subject to reporting requirements under the FEM (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019. Reporting must be done through an authorised dealer bank via the Single Master Form (SMF) available on the Foreign Investment Reporting and Management System (FIRMS) platform. The reporting requirements are summarised as follows:
| Particulars | Form / Return | Purpose / Applicability | Timeline / Remarks | To be Reported By | |
| Reporting for the Issue of Capital Instruments | R-Returns | Reporting of actual inflows on account of the issue of equity instruments | Normal course by the AD branch | AD Branch | |
| Form FC-GPR | Issue of equity instruments to non-residents by an Indian company; applicable for bonus/right shares, cross-border mergers, sweat equity, ESOP conversions, and convertible notes | Within 30 days of the issue of equity instruments in the Single Master Form | Indian Company | ||
| Form FLA (Annual Return on Foreign Liabilities and Assets) | An Indian company or LLP receiving FDI by way of Capital contribution | Submit by 15th July each year via the FLAIR portal with system-driven validation checks | Indian Company/LLP | ||
| Reporting for Transfer of Equity Instruments | R-Returns | Report actual inflows/outflows | Normal course by the AD branch | AD Bank Branch | |
| Form FC-TRS | Transfers of equity instruments between non-resident (holding on a repatriable basis→ non-resident (holding on a non-repatriable basis), and Non-resident → resident | Within 60 days of transfer or fund receipt | Resident transferor/ transferee or PROI holding equity instruments on a non-repatriable basis, as the case may be | ||
| KYC | To ensure the KYC check of the sale consideration in the equity instrument. If a different AD bank receives funds, submit KYC along with FC-TRS In case of a foreign remitter ≠ beneficial owner, then the conditions with respect to. FC-GPR applies | At the time of Receipt of Funds. | KYC Check will be carried out by the AD bank. KYC report to be submitted by the Transferor/transferee to the AD bank carrying out the transaction | ||
| Reporting of Conversion of ECB into Equity | Form FC-GPR & Form ECB-2 | Full conversion of ECB into equity | Within seven working days from the close of the month to which it relates, mark “ECB wholly converted to equity” | Company | |
| Form FC-GPR & Form ECB-2 | Partial conversion | Report converted portion separately; differentiate from non-converted portion | |||
| Form ECB-2 | Subsequent months | Report outstanding ECB | |||
| Reporting of ESOPs and Sweat Equity | Form ESOP | Issue of ESOPs to non-resident employees/directors (or holding/subsidiary companies) | Within 30 days of issue | Issuing Company | |
| Reporting of ADR/GDR Issues | Form DRR | Issue/transfer of sponsored/unsponsored depository receipts | Within 30 days of the close of the issue/program | Domestic Custodian | |
| Reporting Requirements for LLPs | Form FDI-LLP (I) | Reporting for receiving a Capital contribution from a non-resident | Within 30 days; attach FIRC & KYC report | LLP | |
| Form FDI-LLP (II) | Reporting of Disinvestment/transfer between resident and non-resident | Within 60 days; onus on resident transferor/transferee | Resident transferor/transferee | ||
| Reporting of Convertible Notes (CNs) | Form CN | Start-up issuing CNs to non-residents | Within 30 days of issue | Start-up Company | |
| Transfer of CNs between resident and non-resident | Within 30 days, the AD bank is to ensure due diligence/KYC of the foreign investor/buyer | Resident transferor/transferee |
7. Reporting Under Foreign Portfolio Investment
Foreign Portfolio Investments (FPI) in India, other than by NRIs/OCIs, must be reported by AD banks in Form LEC(FII) on a daily basis. Banks are responsible for reconciling submitted data periodically. Equity issued to FPIs considered as FDI is reported separately in Form FC-GPR. Reporting under FPI is summarised hereunder:
| Particulars | Form / Return | Purpose / Applicability | Timeline / Remarks | To be Reported By |
| Reporting of Foreign Portfolio Investment (FPI) | Form LEC(FII) | FPI investments (excluding NRIs/OCIs) under Schedule II of NDI Rules | Daily Basis; AD banks to ensure reconciliation via FPI holding reports | AD Bank |
| Form FC-GPR | An Indian company issuing equity instruments to FPIs is considered FDI | Standard FC-GPR filing rules, i.e. within 30 days of the issue of equity instruments in the Single Master Form | Indian Company | |
| Form LEC(NRI) | Investments by NRIs/OCIs under Schedule III of NDI Rules | Daily basis, the designated AD link office ensures reconciliation via NRI holding reports | AD Bank
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8. Reporting of Investment by NRI
The designated link office of the AD bank must submit a daily report in Form LEC (NRI) to the Reserve Bank, covering all investments made by NRIs/OCIs under Schedule III to the NDI Rules, 2019, classified as Foreign Portfolio Investment under Rule 2(t) of the NDI Rules. The bank is responsible for periodically reconciling the submitted data using NRI holding reports.
9. Reporting of Downstream Investment
Any Indian entity or investment vehicle making a downstream investment in another Indian entity, classified as indirect foreign investment, must file Form DI with the Reserve Bank within 30 days of allotment of equity instruments.
10. Reporting of Investment by Foreign Venture Capital Investor (FVCI)
Investments in equity instruments by Foreign Venture Capital Investors (FVCIs) under Schedule VII of the NDI Rules, 2019 must be reported in Form FC-GPR. Transfers of such capital instruments between an FVCI and a resident in India must be reported in Form FC-TRS. Valuation certificates are not required as pricing guidelines do not apply to Schedule VII investments.
11. Reporting of Investment by Non-Residents in Investment Vehicles
An investment vehicle issuing units to a person resident outside India under Schedule VIII of NDI Rules, 2019 must file Form InVI within 30 days of the issue of units.
12. Reporting of External Commercial Borrowings
Indian companies are permitted to raise funds from abroad through various instruments such as External Commercial Borrowings (ECBs), Foreign Currency Convertible Bonds (FCCBs), Preference Shares, and Foreign Currency Exchangeable Bonds (FCEBs). ECBs may be availed either under the Automatic Route, subject to compliance with the RBI’s prescribed guidelines, or under the Approval Route, which requires prior approval from the RBI. The reporting requirements under the ECB are summarised hereunder:
| Instrument | Reporting Requirement | Form / Mode of Reporting | Timeline |
| External Commercial Borrowings (ECB) | Borrowings under the Automatic or Approval Route to be reported to the RBI | Form ECB (through an AD Category-I bank to RBI) | Within 7 days from the signing of the loan agreement |
| Monthly reporting of actual transactions (drawdown, repayment, interest, charges, etc.) | ECB-2 Return (through AD Category-I bank to RBI) | By the 7th of the following month | |
| Foreign Currency Convertible Bonds (FCCBs) | Reporting of the issue of FCCBs to RBI | Form FC-GPR (via FIRMS portal) | Within 30 days of issue |
| Preference Shares (Non-Convertible/ Redeemable/ Partly Convertible) | Treated as ECB if redeemable; equity if compulsorily convertible. Reporting depends on structure: • Compulsorily Convertible: Report as FDI • Redeemable / Non-Convertible: Report as ECB | Form FC-GPR (for FDI) / Form ECB + ECB-2 Return (for ECB) | 30 days from issue (for FDI) / ECB timelines (for debt nature) |
| Foreign Currency Exchangeable Bonds (FCEBs) | Reporting of the issue of FCEBs to RBI | Form FC-GPR (via FIRMS portal) | Within 30 days of issue |
13. Reporting of Non-Resident Foreign Accounts
The Reserve Bank of India (RBI) requires periodic reporting from AD Category-I banks and authorised banks to monitor remittances, non-resident accounts, and deposits. The reporting obligations are as follows:
| Report / Return | Periodicity / Timeline | To be filed by (Reporting Entity) | Reporting Authority |
| Monthly Statement on Remittances from NRO Accounts (Annexe I) | Monthly – within 7 days of the end of each month | AD Category-I banks | General Manager-in-Charge, Foreign Exchange Department, RBI, Central Office Cell, New Delhi |
| Quarterly Report on Accounts of Bangladeshi Nationals | Quarterly | Head Office of AD banks | Ministry of Home Affairs (Foreigners Division) |
| Monthly Return on Non-Resident Deposits (Annexe II – NRD-CSR) | Monthly, filed on the RBI XBRL platform through: (a) RBI’s NRD-CSR template → .xml upload, or (b) Public/Internal XBRL tool aligned with RBI NRD-CSR discipline. | Authorised banks (through nodal office) | RBI, Department of Statistics and Information Management (DSIM), Central Office
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14. Reporting of Overseas Direct Investment
A Person resident in India who has made an Overseas Investment must comply with various compliance and reporting requirements prescribed under the FEM (Overseas Investment) Regulations, 2022 or any other compliance/reporting guidelines notified by the Reserve Bank of India (RBI). All reporting with respect to overseas investment by a person resident in India shall be made through the designated AD bank as per the revised reporting forms and instructions contained in the “Master Direction – Reporting under Foreign Exchange Management Act, 1999. The list of reports/returns under ODI norms is summarised hereunder
| Form/Report | Purpose | Who should file? | Timeline for Submission |
| Form FC – Sections A, B, C, D & E | Initial reporting of financial commitment in a foreign entity (details of Indian entity, foreign entity, transaction, declaration, auditor’s certificate) | Person resident in India (Indian Entity / Resident Individual) making a financial commitment | At the time of outward remittance or financial commitment, whichever is earlier |
| Form FC – Section F | Reporting restructuring of a foreign entity’s balance sheet involving a diminution in value of dues (equity/debt) | A person resident in India who has made an ODI | Within 30 days of restructuring |
| Form FC – Section G | Reporting disinvestment (sale, transfer, buyback, closure, liquidation, winding up, merger, amalgamation) | A person resident in India undertaking a disinvestment | Within 30 days of receipt of disinvestment proceeds |
| Form FLA | Annual Return on Foreign Liabilities and Assets | Indian Entities which have made ODI in the current or previous years | By 15th July every year |
| Annual Performance Report (APR) | Captures shareholding pattern, financials, repatriation, step-down subsidiaries, and major events | A person resident in India acquiring equity capital in a foreign entity is reckoned as ODI | By 31st December each year (or next year if the foreign entity’s year ends on 31st December) |
| Form OPI | Captures OPI transactions (including by MF, AIF, VCF, ESOP/EBS schemes) | Person resident in India (other than resident individual); also covers Indian Companies, Mutual Funds, AIF/VCF, and OPI under ESOP/EBS | Within 60 days from the end of the half-year (September/March) |
15. Reporting relating to Immovable property
A person resident outside India who establishes a branch, office, project office, or other place of business in India (excluding liaison office) and acquires any immovable property necessary/incidental to its activities is required to file a declaration in Form IPI with the Reserve Bank of India within 90 days from the date of acquisition, as prescribed under the FEMA (Establishment in India of a Branch Office, Liaison Office or Project Office) Regulations, 2016.
16. Reporting of Exports
Export transactions are subject to detailed reporting requirements prescribed by the Reserve Bank of India to ensure transparency, compliance, and proper monitoring of foreign exchange inflows. AD Category–I banks play a pivotal role in collecting and submitting various forms and returns, such as EDF, SOFTEX, EDPMS reports, and export advances. These reporting compliances cover reporting of export of goods, software, long-term contracts, factoring, overdue bills, and e-commerce transactions. Various forms/reports under Export of Goods and Services are summarised hereunder:
| Form/Report | Purpose | Who should file | Timeline for Submission |
| EDF Form | Declaration of export of goods at Non-EDI ports | Exporter | At the time of shipment |
| SOFTEX Form | Declaration of export of software (single or bulk) | Software exporters | Within 30 days from the date of the invoice for software export |
| Annexe III – Advance against Long-term Exports | Reporting receipt of long-term export advances (up to 10 years) | Exporters with ≥ 3-year track record | On receipt of advance; ≥USD 100 million cases to be intimated immediately to RBI |
| Export Factoring – EDPMS | Reporting of export receivables factored on a non-recourse basis | Exporter through AD Bank | As per the transaction reporting cycle in EDPMS |
| Overdue Bills / XOS (via EDPMS) | Monitoring and closure/write-off of overdue export bills | AD Banks (on behalf of exporters) | Continuous, as and when bills are realised/closed |
| EFC Application | Application for opening Exchange Earners’ Foreign Currency (EFC) accounts in India/abroad | Exporters | At the time of the account opening request |
| OPGSP Reporting | Reporting tie-ups with Online Payment Gateway Service Providers for e-commerce exports | AD Category-I Banks | Details to be submitted to RBI, FED, and Central Office upon arrangement |
17. Reporting of Imports
AD Category–I banks have specific reporting obligations in relation to imports, which are monitored by the Reserve Bank of India. These include half-yearly, monthly, and fortnightly submissions covering default in import documentation, gold imports, merchanting trade, online payment gateways, and diamond imports. The returns are filed through designated RBI portals such as XBRL and CIMS. Various returns and reports that are filed by AD banks under the Import provisions are summarised as follows:
| Form / Report | Purpose | Who should file | Timeline for Submission |
| Form BEF via XBRL | Details of import transactions > USD 100,000 where the importer defaulted in submitting import documents within 6 months | AD Category–I Banks (Bank-wide) | Half-yearly (June/Dec) – within 15 days of the half-year end |
| Return Code R133 (HY) via CIMS | Import of gold by EOUs/SEZ/EPZ/nominated agencies (incl. banks); quantity, value, mode of payment-wise | Head Office/International Banking Division of AD Category–I Banks | Half-yearly (end March/Sept) – by the 10th of the following half year |
| Return Code R132 (M) | Import of gold by EOUs/SEZ/EPZ/nominated agencies (other than nominated banks); monthly + cumulative FY position | Head Office/International Banking Division of AD Category–I Banks | Monthly – by the 10th of the following month |
| (Merchanting Trade Defaults Report) | Report of defaults (any leg) in Merchanting Trade transactions | AD Category–I Banks | Half-yearly (June/Dec) – within 15 days of the half-year end |
| R-Return (NOSTRO & VOSTRO) | Reporting OPGSP import transactions, based on invoice & airway bill | AD Category–I Banks | Fortnightly – within 7 days of the end of the fortnight |
| Extension of Time Report (Diamonds) | Report extensions granted beyond 180 days for the import of rough/cut/polished diamonds | AD Category–I Banks | Half-yearly (Apr–Sept, Oct–Mar) – within 15 days of the half-year end |
| (Advance Remittance Report) | Report advance remittances ≥ USD 5 million without BG/SBLC for import of rough diamonds | AD Category–I Banks | Half-yearly – within 15 calendar days of the half-year end |
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