Compliance Calendar
Annual Compliance Calendar for a Foreign Subsidiary in India
Every ROC, RBI and tax filing a foreign-owned Indian company owes in a year — with the statutory deadline, the authority, and what late filing costs.
Last reviewed: July 2026 · Reviewed by CA Regi Tom Antony, Regi Tom Antony & Associates.
What annual filings does a foreign-owned Indian company make?
A foreign-owned Indian company files with three authorities. The Registrar of Companies receives AOC-4, MGT-7, DIR-3 KYC and DPT-3 under the Companies Act, 2013. The Reserve Bank receives FC-GPR, FC-TRS and the annual FLA return under the FEMA (Non-debt Instruments) Rules, 2019. The tax authorities receive the income-tax return, TDS returns and GST returns.
| Filing | Authority | Frequency / due date | Applies to |
|---|---|---|---|
| FC-GPR (issue of shares to non-resident) | RBI — FIRMS portal | Within 30 days of allotment | Every company issuing shares to a non-resident |
| FC-TRS (transfer of shares resident ↔ non-resident) | RBI — FIRMS portal | Within 60 days of receipt/remittance of consideration | On any qualifying share transfer |
| Annual FLA return | RBI — FLAIR portal | 15 July each year (FY ended 31 March) | Every company holding FDI or ODI |
| DPT-3 (return of deposits / exempt monies) | MCA / ROC | 30 June each year | Companies with outstanding loans or receipts of money |
| DIR-3 KYC | MCA / ROC | 30 September each year | Every individual holding a DIN |
| Statutory audit (Companies Act, 2013) | Independent auditor | Before the AGM | Every company, regardless of turnover |
| Annual General Meeting (Section 96) | Company | Within 6 months of financial year end | Every company other than a One Person Company |
| AOC-4 (financial statements) | MCA / ROC | Within 30 days of the AGM | Every company |
| MGT-7 / MGT-7A (annual return) | MCA / ROC | Within 60 days of the AGM | Every company |
| Board meetings (Section 173) | Company | Minimum 4 per year, gap not exceeding 120 days | Every company |
| Income-tax return | Income Tax Department | 31 October (audited companies); 30 November where Form 3CEB applies | Every company |
| Tax audit report (Section 44AB, Form 3CD) | Income Tax Department | 30 September (one month before the ITR due date) | Where turnover thresholds are crossed |
| Transfer pricing report (Form 3CEB) | Income Tax Department | 31 October | Companies with international related-party transactions |
| Quarterly TDS returns (24Q, 26Q, 27Q) | Income Tax Department | 31 Jul, 31 Oct, 31 Jan, 31 May | 27Q covers payments to non-residents |
| GSTR-1 and GSTR-3B | GST Network | Monthly, or quarterly under QRMP | Per GST registration, per state |
| GSTR-9 / GSTR-9C annual return | GST Network | 31 December following the financial year | Above the prescribed turnover thresholds |
Due dates are the ordinary statutory positions as of 2026 and assume a financial year ending 31 March. Extensions notified by the CBDT, MCA or GST Council in a given year override them.
When is the FLA return due to the RBI?
The Foreign Liabilities and Assets return is due by 15 July each year, covering the financial year ended 31 March, and is filed on the RBI FLAIR portal. Every Indian company that has received foreign direct investment or made overseas direct investment must file, even in a year with no fresh inflow and even where accounts are still unaudited.
Where the accounts are not yet audited by 15 July, the return is filed on provisional figures and revised once the audit is complete. Missing the date is a FEMA default, not a mere administrative lapse.
What is FC-GPR and what is its 30-day deadline?
Form FC-GPR reports the issue of equity instruments to a person resident outside India and must be filed on the RBI FIRMS portal within 30 days of allotment, under the FEMA (Non-debt Instruments) Rules, 2019. It carries the board resolution, the company secretary's certificate and, where the pricing guidelines apply, a valuation certificate from a chartered accountant or merchant banker.
FC-GPR — 30 days
From the date of allotment of shares, not from the date the money arrives. Track both dates separately.
FC-TRS — 60 days
On transfer of shares between a resident and a non-resident, from receipt or remittance of consideration.
FLA — 15 July
Annual, on the FLAIR portal, for every company holding FDI — provisional figures accepted if unaudited.
Late submission fee
Delayed FEMA filings can be regularised by paying an LSF computed on the amount and the delay; otherwise compounding applies.
What happens if you miss a filing?
Late FEMA filings such as FC-GPR, FC-TRS and FLA can generally be regularised by paying a late submission fee to the Reserve Bank, calculated on the amount involved and the length of the delay; unregularised contraventions go to compounding. Late MCA forms such as AOC-4 and MGT-7 attract additional fees that accrue for every day of delay.
- 1
Build the calendar at incorporation
Fix the financial year, AGM window and first-audit plan on day one, so AOC-4 and MGT-7 dates fall out automatically.
- 2
Separate the RBI track
FC-GPR, FC-TRS and FLA sit outside the ROC cycle and are the filings foreign parents most often miss.
- 3
Run monthly close discipline
GST and TDS deadlines are monthly and quarterly; a clean close is what makes the annual filings cheap.
- 4
Diary the September–December crunch
DIR-3 KYC, tax audit, ITR, Form 3CEB, AOC-4, MGT-7 and GSTR-9 all land in one quarter.
- 5
Regularise old defaults deliberately
Quantify the LSF or compounding exposure and clear historic FEMA gaps before a funding round or exit diligence.
- 6
Review annually
Thresholds for tax audit, QRMP and GSTR-9C move; re-test applicability each year rather than repeating last year's list.
Who runs this calendar for you
Most foreign parents outsource the whole stack. See India post-entry support for the operating model, audit & compliance for the statutory audit, virtual CFO services for finance leadership, and withholding tax & Form 15CA/15CB for cross-border payments. If you are still choosing the vehicle, start at foreign company formation in India.
Frequently asked questions
What annual filings does a foreign-owned Indian company have to make?
When is the FLA return due to RBI?
What is FC-GPR and its 30-day deadline?
What happens if I miss an FC-GPR or FLA filing?
What is the yearly compliance calendar for an Indian subsidiary?
Reviewed by CA Regi Tom Antony, Regi Tom Antony & Associates. Last reviewed: July 2026. Deadlines are as of 2026 and are general guidance, not advice on your facts.
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