The Annual Performance Report (APR) filing due date for a foreign subsidiary in India is 31st December of each year, covering the financial year ended 31st March. It is mandatory for every Indian resident entity (individuals, companies, LLPs) that has made an Overseas Direct Investment (ODI) under FEMA regulations. Missing this deadline attracts compounding penalties under FEMA. As of 2026, APR must be filed through the RBI's FIRMS portal using the designated APR form.

• Due date: 31st December every year
• Filed on: RBI FIRMS portal under FEMA (ODI) Regulations 2022
• Penalty for non-filing: Up to ₹2 lakh per violation plus continuing penalties under FEMA

What is APR Filing for Foreign Subsidiaries?

The Annual Performance Report (APR) is a compliance report that an Indian entity — company, LLP, or resident individual — must submit to the Reserve Bank of India (RBI) every year for each foreign entity (subsidiary, joint venture, or step-down subsidiary) in which it has made an Overseas Direct Investment (ODI). It captures the financial and operational performance of the overseas entity for the preceding financial year.

APR filing is governed by the Foreign Exchange Management (Overseas Investment) Rules, 2022 and the accompanying RBI FEMA ODI Regulations. The purpose is to give RBI visibility into how Indian capital deployed abroad is being utilised. Every Indian investor that has an active ODI position must comply, regardless of the size of investment.

What is the APR Filing Due Date?

The APR filing due date is 31st December of each calendar year. The report covers the audited financials of the foreign entity for the financial year ending 31st March of that same year — giving Indian entities roughly nine months to compile and submit the report after the overseas books are closed.

Financial Year of Foreign Entity	APR Filing Due Date	Portal
FY 2024-25 (ended 31 March 2025)	31 December 2025	RBI FIRMS Portal
FY 2025-26 (ended 31 March 2026)	31 December 2026	RBI FIRMS Portal

Important: If the foreign entity follows a different financial year (e.g., a calendar year ending 31st December), the APR must be filed within nine months of that entity's financial year-end. Always confirm with your RBI-authorised dealer bank for entity-specific due dates.

Who Must File the APR?

APR filing is mandatory for any Indian resident entity or individual that holds an Overseas Direct Investment in a foreign entity. This includes:

• Indian companies with wholly owned subsidiaries (WOS) abroad
• Indian companies with joint ventures (JV) in foreign countries
• Indian LLPs with overseas investments
• Resident individuals who have made ODI in a foreign entity
• Indian entities holding step-down subsidiary interests abroad

APR must be filed for each foreign entity separately. If your Indian company has three overseas subsidiaries, three individual APR filings are required — one per entity.

What Does the APR Include?

The APR compiles key financial and compliance data from the foreign subsidiary. The report must be backed by audited financial statements of the foreign entity certified by a Chartered Accountant in India.

• Audited balance sheet and profit and loss statement of the foreign entity
• Details of equity, loan, and guarantee remittances made during the year
• Dividend or profit repatriated back to India
• Details of step-down subsidiaries (if any)
• Confirmation of compliance with host-country laws
• Details of write-off of investment, if applicable

If the foreign entity's accounts are not audited (permitted in certain jurisdictions), the APR can be submitted with unaudited financials, subject to RBI approval — but this is the exception, not the rule.

How to File APR on the RBI FIRMS Portal?

Step 1: Access the FIRMS Portal

Log in to the RBI's FIRMS (Foreign Investment Reporting and Management System) portal using your entity credentials. The portal is used for all ODI-related filings including the initial ODI reporting and subsequent APR submissions.

Step 2: Select the Relevant ODI Entity

Navigate to the ODI module and select the specific foreign entity for which the APR is being filed. Each entity is linked to a unique UIN (Unique Identification Number) assigned by RBI at the time of original ODI registration.

Step 3: Upload Audited Financials

Prepare and upload the audited financial statements of the foreign subsidiary. The CA certification is required at this step. Ensure the financials cover the full financial year being reported.

Step 4: Fill in APR Details

Enter all required details — capital structure, remittances, dividend repatriation, step-down subsidiaries, and compliance declarations — directly in the FIRMS portal form.

Step 5: Submit via Authorised Dealer Bank

The completed APR is routed through your Authorised Dealer (AD) Bank for review and forwarding to RBI. Ensure your AD bank has been notified well before the deadline to avoid last-minute rejections.

Penalty for Not Filing APR on Time

Failure to file the APR by the due date is treated as a contravention under FEMA 1999. The penalties can be significant and can compound over time if not addressed promptly.

Violation	Penalty
Non-filing or delayed APR	Up to ₹2 lakh per contravention
Continuing violation (after penalty)	₹5,000 per day until compliance
Compounding application fee	Depends on amount and period of default

Beyond the monetary penalty, non-compliance can also restrict your ability to make further remittances abroad or avail banking facilities for overseas transactions. Timely APR filing is therefore both a legal obligation and a practical necessity for maintaining clean FEMA compliance records.

APR vs. Other ODI Compliance Filings

APR is one of several ongoing compliance obligations under the FEMA ODI framework. Here's how it compares to the other key filings:

Filing	Purpose	Due Date	Who Files
ODI Form (Initial)	Report new overseas investment	Before/at time of remittance	Indian investor entity
APR	Annual performance of foreign entity	31st December each year	Indian investor entity
Form OPI	Report overseas portfolio investments	As prescribed by RBI	Indian investor entity
FLA Return	Foreign Liabilities and Assets survey	15th July each year	Indian company with FDI or ODI

Common Mistakes in APR Filing

• Missing the 31st December deadline due to delayed receipt of audited financials from the foreign entity
• Filing APR without CA certification of the foreign entity's financials
• Not reporting step-down subsidiaries formed by the foreign entity during the year
• Incorrect UIN mapping, resulting in mismatch with original ODI registration data
• Omitting details of loans or guarantees extended to the foreign entity during the year
• Forgetting to file separate APRs for each foreign entity when multiple ODIs exist

How Taxocity Helps with APR Filing

Taxocity has been assisting Indian businesses with FEMA and RBI compliance for over three decades. Our team of real human FEMA experts handles the entire APR filing process — from collecting audited financials of your foreign subsidiary to CA certification, FIRMS portal submission, and AD bank coordination.

• End-to-end APR support: From document collection to final RBI acknowledgement
• 100% compliance guarantee: We track your due date and ensure timely filing every year
• Real human experts: Dedicated FEMA specialists, not automated tools
• Trusted by 5,000+ clients with a 4.8/5 rating
• Additional support for ODI rules for Indian residents with overseas entities, No PE Declarations, and PAN card for foreign companies in India

Whether you have a single foreign subsidiary or multiple overseas entities, Taxocity ensures your APR filings are accurate, certified, and submitted on time — every year, without fail.

Key Takeaways

1. APR filing due date for a foreign subsidiary in India is 31st December of each year.
2. It is mandatory for all Indian entities and individuals with active Overseas Direct Investments (ODI).
3. Filed on the RBI FIRMS portal, routed via the Authorised Dealer Bank.
4. Requires audited financials of the foreign entity, certified by a Chartered Accountant.
5. A separate APR must be filed for each foreign entity in which ODI is held.
6. Non-filing attracts FEMA penalties up to ₹2 lakh plus ₹5,000 per day of continuing violation.
7. Start the process by August/September to avoid year-end bottlenecks with auditors and AD banks.

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Disclaimer: This article is intended for general informational purposes only and does not constitute tax, legal, or financial advice. FEMA regulations and RBI guidelines are subject to periodic revision. Please consult a qualified FEMA advisor or Chartered Accountant for advice specific to your situation before making any compliance decisions.