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⚠️ FEMA Compliance Alert: RBI Offers One-Time Late Submission Fee (LSF) Window Until 21st August 2025
- Sumit ved
- 2 days ago
- 4 min read
📝 Disclaimer: This blog is intended solely for informational purposes. It is based on public notifications and guidelines issued by the Reserve Bank of India (RBI). Please consult your FEMA/Legal/Compliance advisor before acting on the information provided herein.
📢 Attention: Cross-Border Transaction Filers
The Reserve Bank of India (RBI) has issued updated guidelines concerning the Late Submission Fee (LSF) under the Foreign Exchange Management Act (FEMA), 1999 for delayed or missed filings of international transactions.
This presents a one-time opportunity to regularize past non-compliances related to foreign investments and transactions without facing penal action—if filed with LSF by 21st August 2025.
🌍 Who Should Pay Attention?
If you or your clients have entered into any of the following international transactions and have not made timely filings under FEMA, this is directly relevant to you:
✅ FDI – Foreign Direct Investment received in India
✅ ODI – Investment in overseas subsidiaries or joint ventures
✅ ECB – External Commercial Borrowings
✅ Any other cross-border or foreign exchange-related transaction
📑 Common FEMA Returns & Forms Affected
Here are some of the key returns/forms that may be pending and can be regularized with LSF:
🟢 FLA Return – Foreign Liabilities & Assets Return
🟢 APR Return – Annual Performance Report for ODI
🟢 Form FG-GPR – Allotment of shares to foreign investors
🟢 Form FC-TRS – Transfer of shares between resident and non-resident
🟢 Form OPI – Overseas Portfolio Investment
🟢 Form ODI I & II – Overseas Direct Investment declarations
🟢 Form FC – Foreign Currency transactions
🟢 Form LLP (I) – Foreign investment in LLPs
🟢 Form CN, Form DI, Form InVi – Other prescribed forms
🟢 Form ECB / ECB-2 / Revised ECB Return
🟢 Form ESOP – Stock options issued to foreign employees
🟢 Other foreign exchange or non-fund-based transaction filings
📅 Deadline to Avail LSF:
21st August 2025
As per RBI Master Directions and Notification No. FEMA 120/2004-RB, the LSF facility allows delayed filings up to three years from the notification of the Foreign Exchange Management (Overseas Investment) Regulations, 2022.
This facility provides an alternative to penal action—but only if availed within the specified time frame.
⚖️ Consequences of Non-Compliance
Failure to file returns within the due date and failure to utilize the LSF facility will make the entity or individual liable for penal proceedings under the provisions of FEMA, 1999.
This includes:
Monetary penalties
Legal enforcement actions
Restrictions on future cross-border transactions
✅ What Should You Do?
To avoid regulatory scrutiny and penalty exposure:
Review your FEMA compliance history.
Identify any missed filings (even historical ones).
Compile necessary documents such as investment proofs, shareholding patterns, financials, etc.
File the pending returns with the applicable LSF before 21st August 2025.
📌 Final Takeaway
This limited-time LSF window is a significant relief opportunity provided by RBI. Entities and individuals must proactively assess their compliance status and act well in advance of the deadline.
💼 For detailed advice or filing support, please consult your FEMA, legal, or professional advisor.
Stay Compliant. Stay Protected.
— Team [Your Firm Name]
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⚠️ FEMA Compliance Alert: RBI Offers One-Time Late Submission Fee (LSF) Window Until
21st August 2025
📝 Disclaimer: This blog is intended solely for informational purposes. It is based on public notifications and guidelines issued by the Reserve Bank of India (RBI). Please consult your FEMA/Legal/Compliance advisor before acting on the information provided herein.
📢 Attention: Cross-Border Transaction Filers
The Reserve Bank of India (RBI) has issued updated guidelines concerning the Late Submission Fee (LSF) under the Foreign Exchange Management Act (FEMA), 1999 for delayed or missed filings of international transactions.
This presents a one-time opportunity to regularize past non-compliances related to foreign investments and transactions without facing penal action—if filed with LSF by 21st August 2025.
🌍 Who Should Pay Attention?
If you or your clients have entered into any of the following international transactions and have not made timely filings under FEMA, this is directly relevant to you:
✅ FDI – Foreign Direct Investment received in India
✅ ODI – Investment in overseas subsidiaries or joint ventures
✅ ECB – External Commercial Borrowings
✅ Any other cross-border or foreign exchange-related transaction
📑 Common FEMA Returns & Forms Affected
Here are some of the key returns/forms that may be pending and can be regularized with LSF:
🟢 FLA Return – Foreign Liabilities & Assets Return
🟢 APR Return – Annual Performance Report for ODI
🟢 Form FG-GPR – Allotment of shares to foreign investors
🟢 Form FC-TRS – Transfer of shares between resident and non-resident
🟢 Form OPI – Overseas Portfolio Investment
🟢 Form ODI I & II – Overseas Direct Investment declarations
🟢 Form FC – Foreign Currency transactions
🟢 Form LLP (I) – Foreign investment in LLPs
🟢 Form CN, Form DI, Form InVi – Other prescribed forms
🟢 Form ECB / ECB-2 / Revised ECB Return
🟢 Form ESOP – Stock options issued to foreign employees
🟢 Other foreign exchange or non-fund-based transaction filings
📅 Deadline to Avail LSF:
21st August 2025
As per RBI Master Directions and Notification No. FEMA 120/2004-RB, the LSF facility allows delayed filings up to three years from the notification of the Foreign Exchange Management (Overseas Investment) Regulations, 2022.
This facility provides an alternative to penal action—but only if availed within the specified time frame.
⚖️ Consequences of Non-Compliance
Failure to file returns within the due date and failure to utilize the LSF facility will make the entity or individual liable for penal proceedings under the provisions of FEMA, 1999.
This includes:
Monetary penalties
Legal enforcement actions
Restrictions on future cross-border transactions
✅ What Should You Do?
To avoid regulatory scrutiny and penalty exposure:
Review your FEMA compliance history.
Identify any missed filings (even historical ones).
Compile necessary documents such as investment proofs, shareholding patterns, financials, etc.
File the pending returns with the applicable LSF before 21st August 2025.
📌 Final Takeaway
This limited-time LSF window is a significant relief opportunity provided by RBI. Entities and individuals must proactively assess their compliance status and act well in advance of the deadline.
💼 For detailed advice or filing support, please consult your FEMA, legal, or professional advisor.
Stay Compliant. Stay Protected.
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