Every SEZ unit in India must file an Annual Performance Report (APR) with the Development Commissioner of its Special Economic Zone by 30th April each year, covering the previous financial year. The APR tracks export performance, employment, investment, and NFE (Net Foreign Exchange) earnings. Missing this deadline attracts penalties and can jeopardize a unit's Letter of Approval (LoA). Taxocity helps SEZ units prepare and file their APR end-to-end — with a 100% compliance guarantee backed by over three decades of experience.

• Mandatory for all SEZ units irrespective of size or sector
• Due date: 30th April every year (for the preceding financial year)
• Non-filing can result in suspension or cancellation of the LoA

What is an Annual Performance Report (APR)?

The Annual Performance Report (APR) is a mandatory statutory return that every approved unit operating inside a Special Economic Zone must submit to the Development Commissioner. It is prescribed under Rule 22 of the SEZ Rules, 2006, read with the Special Economic Zones Act, 2005. The APR captures the unit's export performance, foreign exchange earnings, employment generated, capital investment, and NFE compliance for the entire financial year.

The Development Commissioner reviews the APR to verify that the unit has met its minimum NFE obligation — a core condition of the LoA. Units that fail the NFE test or do not file the APR face show-cause notices, penalties, and potential de-bonding from the SEZ.

Who Must File the APR for SEZ?

Every SEZ unit that holds a valid Letter of Approval (LoA) from the Development Commissioner must file the APR, regardless of whether it has commenced production or exports. This includes manufacturing units, IT/ITES units, trading units, service-sector units, and developer-operated units inside SEZs.

• IT and ITES companies operating from SEZ campuses
• Export-oriented manufacturing units within SEZs
• Service sector units (financial, legal, consultancy) in SEZs
• Trading units engaged in import/re-export from SEZ
• Units in the process of setting up (even if production has not begun)

What is the Due Date for APR Filing?

As of April 2026, the Annual Performance Report for SEZ units must be filed on or before 30th April of each year, covering the financial year ending 31st March. For example, the APR for FY 2025-26 is due by 30th April 2026.

Financial Year	APR Due Date
FY 2023-24	30th April 2024
FY 2024-25	30th April 2025
FY 2025-26	30th April 2026

Penalties for Non-Filing or Late Filing

The Development Commissioner has the authority to issue a show-cause notice to any SEZ unit that fails to submit the APR by the due date. Consequences include:

• Suspension of the Letter of Approval
• Denial of further duty-free imports and exemptions
• Cancellation of LoA in case of repeated non-compliance
• Recovery of customs duty and tax benefits availed during the year

What is NFE and Why Does It Matter in APR?

Net Foreign Exchange (NFE) earnings represent the net positive foreign exchange a SEZ unit must generate over a five-year block period from its date of commencement. A positive NFE is a mandatory legal requirement under the SEZ Act, 2005. The APR is the primary instrument through which the Development Commissioner verifies NFE compliance each year.

The NFE formula is:

NFE = A – B

• A = FOB (Free on Board) value of exports + value of services rendered in foreign exchange
• B = CIF value of imports + all other payments made in foreign exchange during the year

A unit must maintain a cumulative positive NFE over the first five years. If cumulative NFE turns negative, the unit becomes liable to pay customs duty on all goods imported duty-free. Accurately computing NFE and disclosing it in the APR is therefore critical — even a small calculation error can trigger a large liability.

What is the Format and Documents for APR?

The APR is filed in the format prescribed by the Development Commissioner and typically includes the following schedules:

Schedule	Details Required
Part A – Unit Details	LoA number, date of commencement, nature of activity, sector
Part B – Export Performance	FOB value of exports, shipping bill details, currency-wise breakup
Part C – Import Details	CIF value of capital goods, raw materials, consumables imported
Part D – Employment	Direct and indirect employment generated during the year
Part E – Investment	Capital investment (domestic + FDI) made during the year
Part F – NFE Calculation	Cumulative NFE computation since commencement
Part G – CA Certificate	Chartered Accountant certification of export and import figures

Supporting Documents to Attach

• Audited financial statements for the relevant financial year
• Softex forms / shipping bills / bill of export (as applicable)
• Bank Realisation Certificates (BRCs) or FIRC copies
• Import documents (Bill of Entry, import invoices)
• CA certificate on NFE computation (mandatory)
• Board resolution authorising the signatory
• DSC of the authorised signatory (required for online portal filing)

How to File APR for SEZ Units (2026)

The APR must be filed through the SEZ Online portal (sezindia.nic.in) as well as a physical submission to the Development Commissioner's office. Below are the step-by-step filing instructions:

1. Prepare financial data: Collate audited accounts, export invoices, shipping bills, BRCs, and import records for the full financial year.
2. Compute NFE: Calculate the Net Foreign Exchange earnings using the prescribed formula. Get this certified by a practising Chartered Accountant.
3. Fill the APR form: Enter all details in the prescribed format — unit details, export performance, import details, employment, investment, and NFE workings.
4. Obtain CA certificate: The APR must be countersigned by a Chartered Accountant confirming the accuracy of export and import figures.
5. Submit on SEZ Online portal: Log in to the SEZ Online portal, navigate to the APR section, upload the completed form and attachments, and submit digitally using the authorised DSC.
6. Physical submission: Submit a signed hard copy along with all supporting documents to the Development Commissioner's office before 30th April.
7. Acknowledgement: Collect and retain the acknowledgement receipt issued by the DC's office.

What are Common Mistakes in APR Filing?

• Incorrect NFE calculation due to omitting DTA sales or domestic procurement in "B" component
• Missing or unsigned CA certificate — one of the most frequent grounds for rejection
• Mismatching export figures between shipping bills and audited accounts
• Failure to account for sub-contracting or job work while computing exports
• Not reporting employment figures accurately, which affects MSME and sector statistics
• Delay in BRC submission to the bank, leaving export receipts unreconciled at APR time

How is APR Different from Other Annual Returns?

Compliance	Governing Law	Filed With	Due Date
APR (Annual Performance Report)	SEZ Act 2005 / SEZ Rules 2006	Development Commissioner	30th April
Annual Return (MGT-7)	Companies Act 2013	MCA / Registrar of Companies	60 days from AGM
GST Annual Return (GSTR-9)	CGST Act 2017	GST Portal	31st December
Income Tax Return	Direct Tax Code 2025	Income Tax Portal	31st October (audit cases)

The APR is unique because it is a performance-linked return — non-compliance directly impacts the operational approvals and tax benefits of the SEZ unit, unlike most other statutory returns.

How Taxocity Helps SEZ Units with APR

Taxocity's APR filing service provides complete end-to-end support for SEZ units — from data gathering and NFE computation to CA certification, portal submission, and Development Commissioner liaison. With more than three decades of compliance experience and a 4.8/5 rating from 5,000+ clients, Taxocity brings the expertise that complex SEZ filings demand.

• Expert NFE computation — reviewed by qualified CAs who specialise in SEZ regulations
• 100% compliance guarantee — your APR is filed accurately and on time, every year
• Real human experts — dedicated relationship manager for your SEZ unit's ongoing queries
• End-to-end handling — from document collection to acknowledgement, we manage it all
• Seamless integration with your GST filing and income tax compliance calendar

Taxocity also helps SEZ units stay compliant with related obligations such as GST registration for DTA supplies and quarterly/annual Softex filing — ensuring your unit faces zero regulatory risk.

Key Takeaways

1. APR is mandatory for every SEZ unit under Rule 22 of the SEZ Rules, 2006.
2. The due date is 30th April each year for the preceding financial year.
3. A positive cumulative NFE over the five-year block period is a legal requirement.
4. A CA certificate on NFE computation is compulsory — APR without it is invalid.
5. Filing is done both on the SEZ Online portal and in physical form to the DC's office.
6. Non-filing or negative NFE can lead to duty recovery, LoA suspension, or cancellation.
7. Taxocity provides end-to-end APR filing with a 100% compliance guarantee.

Frequently Asked Questions

Is APR mandatory for new SEZ units that have not started exports?

Yes, all units holding a valid Letter of Approval must file the APR from the year they receive the LoA, even if production or exports have not commenced. They must report nil exports and explain the reason for non-commencement.

Can the APR be revised after filing?

A revised APR can be submitted to the Development Commissioner if errors are discovered after filing. The revision must be supported by fresh CA certification and a covering letter explaining the changes. It is advisable to seek revision promptly rather than wait for a DC query.

What happens if the NFE is negative?

If a unit's cumulative NFE becomes negative at the end of the five-year block period, the unit is liable to pay customs duty on all duty-free goods imported during that period, along with applicable interest. The Development Commissioner issues a demand notice for recovery.

Is GST applicable on exports from an SEZ unit?

Exports from SEZ units are treated as zero-rated supplies under the GST Act. SEZ units can either export with payment of IGST and claim a refund, or export under a bond/LUT without payment of IGST. GST registration is still mandatory for SEZ units making DTA (Domestic Tariff Area) supplies.

Disclaimer

This article is intended for general informational purposes only and does not constitute tax, legal, or financial advice. SEZ regulations and compliance requirements are subject to change. Please consult a qualified tax advisor or compliance expert before making any decisions based on the information provided here.