📄 What is APR in FEMA Compliance?
APR stands for Annual Performance Report, which is a mandatory RBI compliance requirement under the Foreign Exchange Management (Overseas Investment) Rules, 2022.
If you (as an Indian resident individual or company) have made Overseas Direct Investment (ODI) in a foreign JV/WOS, you must file an APR every financial year to report the performance of that foreign entity.
✅ Who Needs to File APR?
APR must be filed if:
- An Indian resident (individual or entity) has made an equity investment (≥10%) in a foreign JV/WOS
- The investment is made under ODI route, not LRS for portfolio investment
- The foreign entity is still active
🔸 APR is filed even if there is no income, profit, or movement in the foreign entity.
📝 What to Report in APR?
APR captures the financial and operational performance of the foreign JV/WOS.
Here’s what must be disclosed:
| Section | What to Report |
|---|---|
| Basic Details | Name of Indian investor, foreign entity, UIN (Unique Identification Number) |
| Equity Holding | % of equity held in the foreign entity by Indian party |
| Financials of Foreign Entity | Turnover, Net Profit/Loss, Total Assets, Total Liabilities |
| Investment Details | Total amount invested by Indian entity (Equity + Loan + Guarantees) |
| Repatriation | Any dividend, profit, or interest repatriated to India |
| Status of the entity | Active / Dormant / Liquidated / Under Closure |
| Audit confirmation | Whether the accounts of the foreign entity are audited or unaudited |
| Other Inflows | Cost recovery, reimbursements (disclose but not considered repatriation) |
| Remarks | Any other relevant notes (e.g., explanation for losses or no activity) |
📅 When to File?
- Due date: By December 31 following the end of the Indian financial year (March 31).
- So, for FY 2024–25 (ending 31 March 2025), APR must be filed by 31 December 2025.
📤 How to File?
APR must be filed online via the AD Bank (Authorised Dealer Bank) through the RBI’s Foreign Investment Reporting and Management System (FIRMS) portal.
Steps:
- Log in to FIRMS (https://firms.rbi.org.in)
- Select “APR” under the ODI module
- Enter required details and attach financials of foreign entity
- Submit and track acknowledgement via your AD Bank
📌 Important Notes:
- Filing APR is mandatory even if the foreign entity has no revenue or activity.
- Non-filing can lead to:
- RBI restrictions on further ODI
- Penalties under FEMA
- APR must be filed for every JV/WOS separately.
✅ Checklist of Documents for APR Filing:
| Document | Required |
|---|---|
| Audited/unaudited financials of JV/WOS | ✅ Yes |
| Ownership details / equity % | ✅ Yes |
| Proof of repatriation (if any) | ✅ Yes |
| Remarks or clarification (if needed) | ✅ Optional |
| Signed declaration by investor | ✅ Yes |
Would you like:
- A sample APR format
- Excel template for data collection
- Help in preparing and filing APR through your AD bank
I can assist with that as well.
