FEMA Compliance Calendar for Foreign-Owned Companies
A practical calendar of FEMA, RBI, Companies Act and tax deadlines for foreign-owned Indian companies, with filing windows, penalties and a checklist.
By Nagavarapu Sudheer, M.Com., F.C.S., L.L.B., Partner, A2 Consultants
Foreign-owned companies in India run on two clocks: event-based FEMA filings that start the day money or shares move, and fixed annual dates that repeat every year. Missing either one leads to late submission fees and, for repeated lapses, compounding. Here is a working calendar for 2026.
Event-based filings
| Event | Form | Window |
|---|---|---|
| Allotment of shares to a foreign investor | FC-GPR (FIRMS portal) | Within 30 days of allotment |
| Transfer of shares between resident and non-resident | FC-TRS | Within 60 days of transfer or receipt of funds |
| Issue of ESOPs to non-resident employees | ESOP reporting | Within 30 days of issue |
| External commercial borrowing | ECB-2 return | Within 7 days of the month end |
Annual dates
| Date | Filing | Applies to |
|---|---|---|
| 15 July | FLA return (FLAIR portal) | Any company that has ever received FDI or made overseas investment |
| 30 September | Annual activity certificate | Liaison, branch and project offices |
| 31 December | Annual performance report | Indian entities with overseas direct investment |
Companies Act and tax dates that sit alongside
- AGM within six months of the financial year end.
- AOC-4 and MGT-7 after the AGM, within the statutory windows.
- Advance tax on 15 June, 15 September, 15 December and 15 March.
- Income tax return by 31 October, or 30 November where transfer pricing applies, with Form 3CEB for international transactions.
What a late filing costs
Late submission is usually regularised through the RBI's late submission fee route rather than compounding. Sources describe a base fee of roughly ₹7,500 plus an amount linked to the delay and the transaction size, with compounding considered after prolonged delay. Treat these figures as indicative and confirm the current RBI master direction.
A simple routine
- Keep a live register of every share issue, transfer, loan and remittance.
- Set reminders 10 days before each window closes.
- Reconcile the FC-GPR and FLA figures with the statutory registers each year.
- Have the statutory auditor and the authorised dealer bank confirm the filings.
- Fix old lapses early through the late submission route, not after a notice.
Note on the new tax law
The Income-tax Act 2025 renumbers many sections and forms. Dates and form names may shift; check the notified version before filing.
How A2 Consultants can help
We run FEMA and RBI filings for foreign-owned companies and maintain a compliance calendar for each client. Get in touch for a compliance health check.
This article is general information, not legal advice. Verify dates and forms against current RBI and government notifications before acting.