Reporting of Foreign Investment in Single Master Form

PUBLISHED ON: 04-01-2023

RBI has released a circular for rationalizing the reporting of foreign investment on the Foreign Investment Reporting and Management System (“FIRMS”) Portal, on January 4, 2023 (available here), and its summary is set out below:

• The forms submitted vide the Single Master Form along with the requisite documents on the FIRMS portal would be auto-acknowledged with time stamp, and an auto-generated email would be sent to the applicant.
• Thereafter, Authorized Dealer Bank (“AD Bank”) would verify the forms and documents submitted on the FIRMS portal, within 5 working days, to ensure that the same are compliant with the extant guidelines. In case of rejection of forms, the remarks of the AD Bank would be communicated to the applicant by a system generated email and can be viewed on the FIRMS portal.
• The system would identify any delay in reporting of the forms, and the AD Banks would advise the applicants either to pay the Late Submission Fee (“LSF”) or compounding of the contravention.
• In case of a delay in submission of the forms, the AD Bank would approve the same if the delay is for a period: (i) less than or equal to 3 years, subject to payment of LSF; (ii) more than 3  years,  subject to  compounding of the contravention,  for which the applicant would subsequently be required to file an application with RBI.
• The LSF amount would be computed by the system and an email would be sent to the applicant with the amount, timeline and process for payment of the LSF to the relevant regional office of RBI.