RBI’s Final Deadline for Regularizing Overseas Investment Reporting Delays

The Reserve Bank of India (RBI) has instructed Authorised Dealer Banks (AD Banks) to notify their clients (Indian Entities / Persons Resident in India) to regularize delays in reporting of Overseas Investment (OI) transactions executed prior to August 22, 2022. This includes filing of Annual Performance Report (APR) which were due for filing as on said date.

The window for regularization, allowing payment of a Late Submission Fee (LSF) instead of undergoing the lengthy compounding process, will close on August 21, 2025.

This initiative, introduced under Regulation 11(2) of the FEMA (Overseas Investment) Regulations, 2022, has offered a three-year period for Indian entities to address any past non-compliance concerning OI transactions. After the deadline, any delays in reporting OI transactions before August 22, 2022, will require either compounding or adjudication.

Key Objectives of the Regularization Window:

1. Facilitate Accurate Reporting: Encourage entities to report past OI transactions accurately, promoting greater transparency in India’s cross-border financial dealings.
2. Reduce Regulatory Backlog: Help address outstanding reporting delays, reducing the overall workload for regulators.
   

What You Need to Do

If your organization has any pending OI transactions to be reported, including filing of Form APR, ensure that you act before August 21, 2025. 

Reach out to your AD Bank to settle any outstanding reporting issues and avoid the complexities of the compounding process. 

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