đź“„ 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.


âś… 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:

SectionWhat to Report
Basic DetailsName of Indian investor, foreign entity, UIN (Unique Identification Number)
Equity Holding% of equity held in the foreign entity by Indian party
Financials of Foreign EntityTurnover, Net Profit/Loss, Total Assets, Total Liabilities
Investment DetailsTotal amount invested by Indian entity (Equity + Loan + Guarantees)
RepatriationAny dividend, profit, or interest repatriated to India
Status of the entityActive / Dormant / Liquidated / Under Closure
Audit confirmationWhether the accounts of the foreign entity are audited or unaudited
Other InflowsCost recovery, reimbursements (disclose but not considered repatriation)
RemarksAny other relevant notes (e.g., explanation for losses or no activity)

đź“… 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:

  1. Log in to FIRMS (https://firms.rbi.org.in)
  2. Select “APR” under the ODI module
  3. Enter required details and attach financials of foreign entity
  4. 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.

âś… Checklist of Documents for APR Filing:

DocumentRequired
Audited/unaudited financials of JV/WOSâś… Yes
Ownership details / equity %âś… Yes
Proof of repatriation (if any)âś… Yes
Remarks or clarification (if needed)âś… Optional
Signed declaration by investorâś… 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.

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