Reference · Deadlines and late fees

Every Indian filing, its deadline, and what being late costs.

A foreign-owned Indian company answers to four different authorities on four different calendars, and none of them sends a reminder. Most of the penalties below accrue daily and a few attach to the directors personally rather than to the company. This page states each deadline plainly, including the ones that catch groups in their first year.

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✓FC-GPR within 30 days of allotting shares · FC-TRS within 60 days of a transfer
✓FLA return by 15 July · ECB-2 monthly · APR by 31 December
✓INC-20A within 180 days — and the company may not trade until it is filed
✓AOC-4 within 30 days of the AGM, MGT-7 within 60 — at ₹100 a day each, uncapped
✓DIR-3 KYC by 30 September, or the DIN is deactivated
✓Form 144 (old 27Q) quarterly · Form 48 (old 3CEB) by 31 October
✓Form 145 and Form 146 (old 15CA / 15CB) before every remittance abroad
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What we handle for you

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RBI and FEMA

FC-GPR, FC-TRS, the annual FLA return, monthly ECB-2 where there is a loan, Form DI for a downstream investment, and the APR where the Indian company has invested abroad.

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Registrar of Companies

INC-20A before trading, ADT-1 for the auditor, AOC-4 and MGT-7 after the AGM, and DIR-3 KYC for every director holding a DIN.

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Income tax

Quarterly withholding statements, the tax audit report, the accountant's report where transfer pricing applies, and the return itself.

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Every outward remittance

The declaration and, where required, the accountant's certificate — filed before the money leaves, not after.

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What late actually costs

Daily additional fees with no ceiling at the Registrar, a fixed fee and a deactivated DIN for late KYC, and a formula-based Late Submission Fee for delayed RBI reporting.

Who this is for

🏢 Foreign-owned subsidiaries

Especially in the first year, where the one-off filings sit.

📊 Group finance teams

Needing the India calendar in a form head office can track.

🏤 Liaison and branch offices

Which have their own annual certificate on top.

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Common questions

When is FC-GPR due? FC-GPR applicability and deadline

FC-GPR is filed within 30 days of allotting shares to a non-resident, and it applies to every issue of equity instruments to a person resident outside India — including the first allotment to the subscribers on incorporation, which is the one most often missed. It is filed on the Reserve Bank's FIRMS portal, and the Entity Master registration has to exist before you can file it. The filing needs the FIRC and KYC from the bank and the valuation certificate.

When is FC-TRS due? FC-TRS applicability and deadline

Within 60 days of the transfer of shares or of the consideration being received, whichever happens first. It applies where shares move between a resident and a non-resident, in either direction; a transfer from one non-resident to another does not require it. The obligation sits with the resident party, or with the non-resident acquiring on a non-repatriable basis, so a foreign seller should confirm it has actually been filed rather than assume.

When is the FLA return due?

By 15 July each year, for the financial year ended on the preceding 31 March. Every Indian company that has received foreign investment or made an overseas investment has to file it — including a company with no activity at all that year, which is why dormant subsidiaries fall foul of it. If you file on unaudited figures because the audit is not finished, a revised return is due by 30 September once the accounts are signed.

When is the ECB-2 return due?

Monthly, within seven working days of the end of each month, for as long as an external commercial borrowing is outstanding. It starts once the loan registration number is issued and continues until the loan is fully repaid, whether or not anything moved that month. A parent loan to an Indian subsidiary is the usual reason a group finds itself with a monthly RBI return it did not expect.

What is Entity Master registration on the FIRMS portal?

A one-off registration of the Indian company on the Reserve Bank's FIRMS portal, with no recurring due date, which has to exist before any FDI filing can be made. It records the company's details and its foreign investment position, and it is maintained by an authorised person at the company. Leaving it until the day FC-GPR falls due is a common reason that 30-day window is missed.

When is Form DI due for a downstream investment?

Within 30 days of the allotment or acquisition. It applies where your Indian company — itself foreign owned — invests in another Indian company, because that second investment carries the foreign ownership with it. Groups that set up a second Indian entity for a new line of business routinely miss this one entirely.

When is the APR due for an ODI (overseas direct investment)?

By 31 December each year, where the Indian company holds an overseas direct investment (ODI) outside India. It is filed through the authorised dealer bank on the basis of the overseas entity's audited accounts. Less common for an inbound group, but it bites where the Indian subsidiary itself has set up or acquired something abroad.

What is LSF (Late Submission Fee), and when is compounding needed instead?

Where an RBI reporting form is simply late, the delay is usually regularised by paying a Late Submission Fee, or LSF — a formula-based amount driven by the sum involved and the length of the delay, payable once the Reserve Bank advises it. It is a fee schedule rather than a hearing, and it closes the matter. Where the breach is substantive rather than merely late, or falls outside what the fee covers, the route is a compounding application to the RBI: you disclose it, an order is passed and a penalty is paid. Both are far better than leaving it undisclosed for a buyer to find.

When is INC-20A due, and what is the penalty?

Within 180 days of incorporation, and this is the one that stops a company trading. Until the subscribers have actually paid for their shares and this declaration is filed, the company may not begin business or borrow. The penalty is ₹50,000 on the company and ₹1,000 per day on each officer in default up to ₹1,00,000 — entirely avoidable, and regularly incurred by groups waiting on a bank account.

When is ADT-1 due?

Within 15 days of the meeting at which the auditor is appointed. The first auditor is appointed by the board within 30 days of incorporation, and the Ministry's position is that ADT-1 is not strictly required for that first appointment, though many companies file it anyway for the record. For every appointment made at an annual general meeting afterwards, the 15-day filing does apply.

When is AOC-4 due?

Within 30 days of the annual general meeting. For a company with a 31 March year end the AGM must be held by 30 September, so AOC-4 is typically due by 30 October — with the first AGM allowed up to nine months after the first financial year end. The additional fee for late filing is ₹100 per day with no upper limit, which is why a forgotten filing becomes expensive rather than merely irritating.

When is MGT-7 due?

Within 60 days of the annual general meeting, so typically by 29 November for a 31 March year end. Smaller companies file the shorter MGT-7A. The late fee is the same ₹100 per day per form, uncapped, and it runs alongside the AOC-4 fee rather than instead of it — so a company that files both a year late pays twice over.

When is DIR-3 KYC due for a foreign director?

By 30 September each year, for anyone who held a Director Identification Number as at the preceding 31 March — foreign directors included, wherever they live. Miss it and the DIN is deactivated, which blocks every filing that director has to sign, and reactivation costs a ₹5,000 fee. It takes minutes and it is the single most common reason a foreign-owned company cannot file something urgent.

How does a foreign director get a DSC and register it on the MCA portal?

Two steps, and people stop after the first. A Class 3 digital signature is obtained from a licensed Indian certifying authority, supported by an apostilled or consularised passport and address proof and a short video verification — no visit to India is needed. It then has to be associated with your role on the MCA portal as a registered user before it will sign anything. A certificate that exists but has never been registered against the DIN is the single most common reason a filing cannot be signed on the day it is due.

Does a foreign director have to pay professional tax?

It depends on the state and on whether the director draws anything. Professional tax is a state levy and only about half the states impose it — Maharashtra, Karnataka, West Bengal, Tamil Nadu, Gujarat and Telangana among them, while Delhi and Uttar Pradesh do not. A non-resident director drawing no remuneration or sitting fees is generally outside it, but the company itself usually has its own enrolment obligation in a state that levies it, independent of the directors. The amounts are small and capped; the registration is the part that gets missed.

When is Form 27Q due?

Quarterly — 31 July, 31 October, 31 January, and 31 May for the final quarter. It is the statement of tax deducted on payments to non-residents, and under the Income-tax Rules, 2026 it is now Form 144. You need a TAN to file it, and a buyer purchasing property from a non-resident seller needs one for this reason.

When is Form 3CEB due?

By 31 October, one month ahead of the return itself, which is due by 30 November where transfer pricing applies. It is the accountant's report on international transactions with related parties, now Form 48 under the Income-tax Rules, 2026. Any payment to your foreign parent — a management fee, a royalty, interest, or goods — brings it into play, and the threshold is lower than most groups assume.

When must Form 15CA and 15CB be filed?

Before the money leaves India, not afterwards. The declaration is filed by the remitter and the accountant's certificate, where required, is obtained first — the bank will ask for the acknowledgement as a condition of processing the remittance. They are now Forms 145 and 146 under the Income-tax Rules, 2026. Leaving them to the day of the transfer is what delays remittances.

When is the Annual Activity Certificate due for a liaison or branch office?

By 30 September each year, together with the audited accounts, submitted to the authorised dealer bank and to the Director General of Income Tax (International Taxation). It is a certificate from a chartered accountant confirming that the office has operated only within the activities the Reserve Bank permitted it. A liaison office that has drifted into anything resembling trading will find this is where it surfaces.

When are the tax audit report and the company return due?

The tax audit report by 30 September and the return by 31 October, or 30 November where transfer pricing applies. Separately, and independently of any threshold, every Indian company has a statutory audit under the Companies Act every year regardless of turnover — including a dormant one. Groups sometimes assume a small or inactive subsidiary escapes audit; it does not.

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