What RBI/FEMA documentation is needed for a change in foreign shareholding?

Whenever foreign shareholding in an Indian company changes — whether through a fresh share issue or a transfer of existing shares — FEMA requires the transaction to be reported. For share transfers between a resident and non-resident, this includes reporting the transfer to the Reserve Bank of India through the company, so RBI's records of the company's ownership stay current.

This filing runs on its own track, independent of the withholding tax return, the share transfer stamp duty, and the company-law paperwork for updating the register of members — missing it doesn't stop the shares from changing hands, but it does leave a compliance gap that surfaces on a later audit or subsequent transaction.