The FEMA reporting forms we file
The most common FEMA reporting forms for Indian companies and LLPs:
- FCGPR — Foreign Currency General Permission Route. Filed within 30 days of share allotment to a non-resident.
- FCTRS — Foreign Currency Transfer of Shares. Filed within 60 days of share transfer between a resident and a non-resident.
- ECB-2 — monthly return for External Commercial Borrowings.
- FLA — Annual Return on Foreign Liabilities and Assets, by 15 July each year.
- ODI returns — for Overseas Direct Investment by Indian companies.
- APR (FEMA) — Annual Performance Report for ODI.
- Form ESOP — for ESOP allotment to foreign employees.
Entities with FEMA reporting exposure
Every Indian company that has received foreign equity (one-time or recurring); every LLP that has accepted foreign capital contribution; every borrower with ECB exposure; every Indian outbound investor with overseas subsidiaries / JVs; every Indian company with foreign-employee ESOP grants; every entity with foreign assets or liabilities at year-end.
Notifications, Master Directions & the SMF portal
The relevant references:
- FEMA Notification 20(R)/2017 — Non-Debt Instruments Rules — FCGPR, FCTRS pricing.
- RBI Master Direction on Reporting — current SMF (Single Master Form) procedures.
- FEMA Notification 3(R)/2018 — ECB framework.
- FEMA Notification 120 (now superseded) — Overseas Investment Rules 2022.
- SMF / Firms portal — Single Master Form for FDI reporting.
How we run a FEMA filing end-to-end
- Pre-allotment / pre-transfer review — FDI route, sector cap, pricing, eligible instruments.
- FIRC & KYC pack — we coordinate with the AD bank for the FIRC and KYC documentation.
- Pricing certificate by Merchant Banker / CA under Rule 21 (where applicable).
- FCGPR / FCTRS filing via the SMF portal within statutory timelines.
- RBI / AD-bank queries — we respond on behalf of the client, marshal additional documentation.
- Annual FLA filing by 15 July.
- ECB-2 monthly for borrowers.
- Compounding application if a delay has already happened — we present the case before RBI compounding authority.
What you’ll need to share
- Share allotment / transfer board resolution and minutes.
- FIRC and KYC from AD bank.
- Share certificates and transfer deeds.
- Pricing certificate (Rule 21 valuation).
- Foreign investor’s incorporation documents (apostilled / consularised).
- For ECB: loan agreement, LRN allotment letter, drawdown schedule.
- For FLA: balance-sheet schedules of all foreign assets and liabilities.
How long & how we charge
FCGPR / FCTRS turnaround on the SMF portal is 7–15 working days for clean filings. We start the documentation 5–7 working days before the statutory due date. Compounding applications run 60–120 days. Fixed-fee per filing; annual retainer for clients with recurring transactions.
Common questions on FEMA filings
What happens if FCGPR is filed late?
Late submission fee under the LSF mechanism — capped multipliers depending on the delay window. After a year of delay, compounding application to RBI is required. We resolve both routes.
Is FLA mandatory if the foreign holding has reduced to zero?
Yes — if foreign assets / liabilities existed at any time during the year. The form captures both opening and closing balances.
Does ECB include trade credits and other short-term borrowings?
Trade credits up to one year are reported under different forms (Trade Credit Reporting). ECB is for external commercial loans of more than 1 year. We map each borrowing correctly.
Can the same firm advise on FDI structuring and file FCGPR?
Yes. The structuring leads to a clean filing; we keep the same team across both.
Talk to a partner.
A 30-minute call with a partner — no deck, no follow-up email blasts. Just a read on whether we’re the right team to handle your FEMA filings.