FEMA Due Date Calendar
FC-GPR, FC-TRS, ECB-2, APR and SMF filing deadlines.
The FEMA Due Date Calendar lists key FEMA compliance deadlines for FDI, ODI and ECB reporting, such as FC-GPR, FC-TRS and ECB-2, along with the FLA annual return and export realisation. It is for companies with foreign investment or borrowings and their compliance teams. Delayed filings can generally be regularised within three years by paying a Late Submission Fee of Rs 7,500, plus 0.025% of the amount involved per year of delay for transaction returns.
Use the FEMA Due Date Calendar
Important due dates for FEMA compliance — FDI / ODI / ECB reporting, FLA annual return, and export realisation. Delayed filings attract a Late Submission Fee (LSF) under RBI's uniform LSF framework.
| Form | Description | Due Date | Category |
|---|---|---|---|
| FC-GPR | Foreign Direct Investment receipt - filing of share allotment | Within 30 days of allotment | FDI Inflow |
| FC-TRS | Transfer of shares between resident and non-resident | Within 60 days of transfer or receipt / remittance of funds, whichever is earlier | FDI Transfer |
| Form FC (ODI) | Overseas Direct Investment - financial commitment reporting to AD bank (UIN allotment) | At the time of making the financial commitment | ODI |
| APR (Form ODI Part II) | Annual Performance Report for foreign entity (subsidiary / JV) | 31 December every year | ODI Annual |
| FLA Return | Foreign Liabilities and Assets - annual return to RBI | 15 July (for previous FY) | Annual |
| ECB 2 | ECB drawdown / debt-servicing return | Within 7 calendar days from end of month of transaction | ECB |
| ECB 1 | ECB - Loan Registration Number (LRN) application through AD bank | Before first drawdown | ECB |
| EDF (new 2026) | Unified Export Declaration Form (goods + services + software) | At time of export (from 1 Oct 2026) | Export |
| BRC/eBRC | Bank Realisation Certificate - export proceeds realised | Within 9 months of export (12 months if INR-invoiced, exports from 1 Oct 2026; 15 months for exports 13 Nov 2025 - 4 Jun 2026) | Export |
| Schedule FA | Foreign Assets / Income disclosure in ITR (assets held at any time in the calendar year ending 31 December) | With ITR: 31 July; 31 August for business or profession not audited (Finance Act 2026, from AY 2026-27); 31 October for audit cases | Annual |
| Form 15CA / CB | Foreign remittance certificate (now Form 145 / 146 from TY 2026-27) | Before each foreign remittance | TDS/Remittance |
Late Submission Fee (LSF) framework:
Under RBI A.P. (DIR Series) Circular No. 16 dated 30 September 2022 (uniform LSF across FDI, ECB and ODI reporting), a delayed return can be regularised by paying an LSF instead of compounding:
- Returns capturing transactions / flows (e.g. FC-GPR, FC-TRS, Form FC / ODI Part I, ODI Part III, ECB 2, Form DI, Form InVi): LSF = ₹7,500 + (0.025% × A × n), where A is the amount involved in the delayed reporting and n is the delay in years, rounded up to the nearest month and expressed up to two decimals. The LSF is capped at 100% of A and rounded up to the nearest hundred.
- Other returns (e.g. APR / Form ODI Part II, FLA return, Form OPI, evidence of investment, ECB 1): flat ₹7,500 per return.
- Time limit: LSF is available only up to three years from the due date of reporting. Beyond that, the delay must be regularised through compounding under Section 15 of FEMA.
- ECB 2: each delayed ECB 2 return under a Loan Registration Number is treated as a separate instance for LSF (A.P. (DIR Series) Circular No. 25 dated 30 March 2026).
Upcoming: FEMA Export/Import Regulations 2026 — effective 1 October 2026. Will replace the 2015 regulations and introduce a unified Export Declaration Form (EDF) covering goods, services, and software. Realisation period for exports from 1 October 2026: 9 months (12 months if invoiced / settled in INR), as amended by Notification FEMA 23(R)/(1)/2026-RB dated 22 September 2026. Watch for transitional guidance from RBI.
Important note: This tool provides an indicative output only. It does not factor in every special provision, surcharge, exception, or recent notification. Verify with the firm before acting on any computation.
Frequently Asked Questions
When is the FLA return due?
The annual return on Foreign Liabilities and Assets (FLA) must be filed with the RBI by 15 July each year, based on audited or provisional accounts. If the audit is not complete by then, the return is filed on provisional or unaudited figures and revised through the FLAIR portal, with RBI's permission, once the accounts are audited. It applies to entities that have received FDI or made overseas investment.
What is the time limit for reporting FDI share allotments?
Equity instruments must be allotted within 60 days of receiving funds from the foreign investor, and Form FC-GPR must be filed on the RBI FIRMS portal within 30 days of allotment. Transfers of shares between residents and non-residents are reported in Form FC-TRS within 60 days of the transfer or receipt of funds, whichever is earlier.
Within what period must export proceeds be realised?
Export proceeds must generally be realised and repatriated to India within nine months from the date of export; from 1 October 2026 the period is 12 months where the export is invoiced or settled in rupees, and exports made from 13 November 2025 to 4 June 2026 had 15 months. For goods sent to an overseas warehouse, the period runs from the date the goods are sold from the warehouse for exports from 1 October 2026. Extensions can be sought through the authorised dealer bank, and outstanding shipments are tracked through the EDPMS system.
What are the ECB reporting requirements?
Under the ECB framework as amended from 16 February 2026, a borrower must obtain a Loan Registration Number (LRN) by filing Form ECB 1 through its authorised dealer bank before any drawdown. Thereafter, Form ECB 2 must be filed within seven calendar days from the end of the month in which a drawdown, repayment or other debt-servicing transaction takes place.
How is the Late Submission Fee for delayed FEMA reporting calculated?
Under RBI's uniform framework of 30 September 2022, the fee for returns that report transactions, such as FC-GPR, FC-TRS and ECB 2, is Rs 7,500 plus 0.025% of the amount involved multiplied by the years of delay, capped at the amount involved. Other returns, such as the APR and FLA return, attract a flat Rs 7,500. The fee route is available only up to three years from the due date; after that, compounding is needed.
Due in the next 30 days
FEMAFull compliance calendar → Statutory dates, which can be extended by notification. General information only.