Reporting on FIRMS portal – Issuance of Partly Paid Units by Investment Vehicles

Notification/Circular No.: RBI/2025-26/40, A.P. (DIR Series) Circular No. 06 dated May 23,2025

Applicable Act/Rule: Foreign Exchange Management Act, 1999; Foreign Exchange Management (Non-debt Instruments) Rules, 2019

Ministry of Finance amended the Foreign Exchange Management (Non-debt Instruments) Rules, 2019 in March 2024 to permit investment vehicles to issue partly paid units to persons resident outside India. RBI is now providing a one-time reporting window and clarifying the obligations for investment vehicles with respect to these issuances.

Investment vehicles that have issued partly paid units to foreign investors before May 23, 2025 are now allowed to report these transactions in Form InVI on the FIRMS portal within 180 days from the date of this circular. No late submission fees will apply if the reporting is done within this window.

For issuances made on or after May 23, 2025, the existing timeline of 30 days from the date of issuance will continue to apply, as per Regulation 4(10) of the FEMA (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019.

Authorised Dealer Category-I banks are required to inform their customers of these changes.

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