ODI is not finished when the remittance hits the UAE or UK account. Each foreign entity you hold as ODI needs an APR that matches its financial statements — or a documented reason it is not due yet (for example, the entity is too new, or a specific exemption in the live directions applies). Missing APR is one of the cleanest LSF files we see, because the delay is obvious.
This page is APR — not FC-GPR (inbound allotment) and not FLA (foreign liabilities and assets of the Indian entity). Those are different forms, different clocks, and different late-fee rules. We will not merge them to rank for “FEMA due dates.”
How this page differs
- APR-only — not a mash-up of FC-GPR, FC-TRS, FLA, and ECB.
- Due-date language that defers to the live Master Direction instead of freezing a calendar cell we would have to patch every year.
- Links LSF when the APR is late and ODI vs OPI when the entity was misclassified.
Who this is for
- Indian companies with a Dubai, UK, Singapore, or US subsidiary
- Resident individuals who made ODI into an unlisted foreign entity
- Groups that filed the first remittance and then went silent
- Auditors asking whether last year’s APR exists before they sign the Indian accounts
How we work
- 01
List every ODI foreign entity
Step-downs included where the directions require them. OPI holdings are not APR entities.
- 02
Pull local accounts
The APR wants financials that exist — management accounts if statutory accounts are still open, with a note. Invented turnover is worse than a late filing.
- 03
File through the AD bank
PJRJ prepares the pack. The bank submits. If late, we run the LSF eligibility test instead of pretending the portal will ignore the calendar.
What you receive
- Entity-wise APR tracker
- Numbers pack aligned with foreign accounts and Indian books
- AD-bank submission support
- LSF working if the due date is already gone
Due date — confirm, do not memorise a landing page
Practitioners commonly work to a 31 December deadline following the foreign entity’s year, as set out in RBI’s overseas-investment directions. That sentence is a pointer, not a substitute for the paragraph in force on the day you file. If RBI moves the date or the portal shows a different clock, the portal and the direction win.
First-year APRs sometimes follow a different “from the date of investment” logic in the directions. Newly acquired entities, liquidations, and write-offs have their own reporting. We read the paragraph that matches the event rather than recycling last year’s tracker.
Related filings people confuse with APR — each has its own clock.
| Filing | Whose story? | Usual trigger | Late path |
|---|---|---|---|
| APR | Each foreign ODI entity | Annual performance / financials | Often LSF if eligible |
| ODI Form (investment) | The remittance / acquisition | At the time of ODI | LSF / compounding per directions |
| FLA | Indian entity’s foreign assets & liabilities | Annual, typically mid-year — confirm live date | FLA late-reporting rules, not APR’s |
| FC-GPR | Indian company allotting to a non-resident | Inbound FDI allotment | FDI LSF grid |
| 15CA/CB | Income-tax remittance information | Outward remittance when required | Tax default — not LSF |
What the numbers must match
Shareholding on the APR should match the foreign register and the Indian ODI stock. Turnover and profit should match the accounts you would give a banker. Downstream investments should not appear as a surprise. If the UK Ltd’s accounts are in GBP, we keep the FX policy explicit rather than mixing rates across rows.
Common questions
Direct answers for searchers and answer engines
Nil activity is still a report if the ODI entity exists and the directions require APR. “No operations” is a line in the form, not an exemption you assume.
No. Submission is through the AD bank. We prepare the working papers and the form content the bank requires.
Each year is a separate report. We stack the filings and test LSF year-wise. We do not hide two years inside one PDF.