RBI Compliance & FEMA Reporting

Annual Performance
Report (APR)
Filing Services

End-to-end APR filing advisory — from FDI/ODI compliance review and Single Master Form preparation to FC-TRS filing, Authorized Dealer bank coordination, and FEMA regulatory reporting for Indian companies with foreign investment.

35+

Years of Practice

3

APR Filing Types

2

Office Locations

7+

APR Service Areas

  • APR-FDI, APR-ODI & APR-LLP filing
  • FEMA compliance review & FC-TRS filing
  • Single Master Form portal submission
  • AD bank coordination & regulatory advisory

What is APR Filing?

Annual Performance Report (APR) is a mandatory annual return filed with the Reserve Bank of India (RBI) by Indian companies that have received Foreign Direct Investment (FDI) or made Overseas Direct Investment (ODI). Required under FEMA regulations, APR enables RBI to monitor and compile data on foreign investment flows into and out of India.

The report captures details of foreign investment received, shareholding pattern, financial performance, compliance with sectoral conditions, downstream investments, and guarantees issued. APR must be filed annually through RBI's Single Master Form (SMF) portal.

Our Services

APR Filing Services
We Provide

From APR preparation and FEMA compliance review to FC-TRS filing and downstream investment advisory — complete RBI reporting support.

01

APR Preparation & Filing

Review of foreign investment transactions, compilation of required documents, APR form preparation on Single Master Form portal, financial data validation, AD bank coordination, and filing submission with acknowledgement receipt.

FDI Review • Data Entry • SMF Portal • AD Bank

02

FEMA Compliance Review

Review of all foreign investment transactions, FC-TRS filing status verification, compliance with sectoral caps and FDI conditions, downstream investment compliance check, and identification of gaps with remedial action recommendations.

FDI Conditions • Sectoral Caps • FC-TRS • Gap Analysis

03

Delayed APR Filing Support

Identification of pending APR years, data reconstruction for previous years, RBI and AD bank coordination for delayed filings, and regularization of compliance status to avoid issues in future transactions.

Pending Years • Data Reconstruction • RBI Coordination • Regularization

04

FC-TRS Filing Services

FC-TRS filing for share issuance to foreign investors and share transfers between residents and non-residents. Documentation preparation, valuation compliance verification, AD bank filing, and acknowledgement tracking.

Share Issuance • Transfers • Valuation • AD Bank Filing

05

ODI Compliance & Reporting

ODI approval verification and compliance with investment limits, repatriation monitoring, financial statement consolidation, APR-ODI preparation and filing, and RBI reporting for ODI transactions and annual returns.

ODI Approval • Repatriation • APR-ODI • RBI Reporting

06

Downstream Investment Advisory

Review of downstream investment structure, compliance with downstream investment limits, APR reporting for downstream entities, and indirect foreign investment calculations for regulatory compliance.

Structure Review • Investment Limits • APR Reporting • Indirect FI

07

Sector-Specific FDI Compliance

Advisory on sector-specific FDI conditions including defence, retail, real estate, broadcasting, media, print, insurance, banking, and multi-brand retail compliance requirements and restrictions.

Defence • Retail • Real Estate • Broadcasting • Banking

Filing Process

APR Filing Process — Single Master Form

STEP 1

Data Compilation

Gather foreign investment details, financial statements, FC-TRS acknowledgements, downstream investment data.

STEP 2

Portal Registration

Register company on SMF portal through AD bank, obtain login credentials, arrange Digital Signature Certificate.

STEP 3

Form Preparation

Select appropriate APR form (FDI/ODI/LLP), fill required information, upload financial data and documents.

STEP 4

Validation & Submission

Review data accuracy, resolve errors, digitally sign, submit through portal, coordinate with AD bank.

Technology & IT Services Healthcare & Pharma Manufacturing Financial Services Consumer & Retail Infrastructure & Real Estate

Regulatory Framework

Governing Laws &
RBI Directions

APR filing is governed by FEMA, RBI Master Directions, Companies Act, and Consolidated FDI Policy. Our team ensures full compliance across all applicable regulations and circulars.

FEMA, 1999

Foreign Exchange Management (Non-debt Instruments) Rules, 2019 — core framework for FDI reporting.

RBI Master Directions

Master Direction on Foreign Investment in India and Reporting under FEMA.

Companies Act, 2013

Provisions relating to foreign investment, share transfers, and corporate compliance.

Consolidated FDI Policy

Sectoral caps, entry routes, and conditions for foreign investment in India.

Common Questions

Frequently Asked Questions

QWhat is APR filing and who needs to file it?

APR (Annual Performance Report) is an annual return filed with RBI by Indian companies that have received Foreign Direct Investment (FDI) or made Overseas Direct Investment (ODI). All companies with foreign shareholders or overseas investments must file APR.

QWhen is the APR filing deadline?

The APR is due by December 31 annually. If the financial year ends on December 31, the APR is due by December 31 of the following year. Late filing may attract late submission fees.

QWhat happens if APR is not filed on time?

Late filing may attract penalties, late submission fees, and operational difficulties in future foreign exchange transactions including repatriation, future foreign investment, and ODI applications.

QWhich portal is used for APR filing?

APR is filed through RBI's Single Master Form (SMF) portal accessible at firms.rbi.org.in. Companies must register on the portal through their Authorized Dealer bank.

QWhat is FC-TRS and how is it related to APR?

FC-TRS (Foreign Currency Transfer of Shares) is a reporting form filed for each foreign investment transaction. APR captures consolidated data from all FC-TRS filings during the year. Companies must file FC-TRS before filing APR.

QCan historical pending APRs be filed?

Yes, delayed APRs can be filed with late fees. Companies should regularize pending APR filings to avoid compliance issues in future transactions.

Beyond APR

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Ready for APR
Filing?

Get in touch to discuss your APR filing, FEMA compliance, or RBI reporting requirements. We serve businesses across India.

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