Your Indian company is investing abroad. RBI wants a report on it every year, forever

If your company has NRI or foreign shareholders, you may already know about FC-GPR, FC-TRS and the FLA return, the filings that report foreign money coming INTO your Indian company, on the RBI's FIRMS and FLAIR portals. This is the reverse flow: your Indian company sending money OUT, to a foreign entity it now owns or has invested in. It's reported through a separate RBI system built for outbound investment, tied to a Unique Identification Number (UIN) issued for that specific investment, and it's easy to assume that because the inbound filings are handled, the outbound side must be too. It isn't automatically. They're separate obligations, on separate systems, triggered by opposite directions of money.

Form FC reports the investment itself, filed at the time of financial commitment or the first remittance, whichever happens first. The detail that catches people out: a "financial commitment" is treated as created once a binding obligation exists, signing the incorporation documents for a new foreign entity or the acquisition agreement for an existing one, even before any money has actually left India. Waiting until the wire transfer to think about the filing can mean the clock already started weeks earlier.

Once the investment exists, an Annual Performance Report, filed as Form ODI Part II, is due every year by 31 December, built from the foreign entity's audited financial statements, for as long as the investment is held. The instinct in a genuinely quiet year, the US LLC did nothing, the Singapore entity is pre-revenue, is that there's nothing to report. RBI doesn't recognise that as an exemption. A dormant or loss-making year still needs an APR reflecting that dormancy or loss, not a skipped filing. This runs on the calendar, not on activity, the same discipline the FLA return already demands on the inbound side.

A missed APR isn't lost, it's filed late with a flat Rs 7,500 Late Submission Fee, available for up to 3 years from the original due date. Past that window, the route becomes a formal compounding application to the RBI instead, a heavier process with its own fee and timeline. The consequence worth taking seriously now is a 2025 tightening under Regulation 12: an unresolved past reporting lapse tied to a specific investment's UIN can now block your company from making any NEW financial commitment against that same UIN, not just draw a late fee on the old one, until the gap is actually regularised. A company that assumed a years-old, unfiled APR was a dormant problem can find it's an active one the moment it tries to fund the next tranche, open a second foreign entity, or extend a loan to the one it already has.