Late Submission Fee Under FEMA in 2026 with Formula and Examples

Written by CA Nandini Hasija, Krystal7 Consultants. Last updated 23 October 2026.

The late submission fee (LSF) under FEMA is INR 7,500 plus 0.025 percent of the amount involved for each year of delay. It applies to flow returns such as Form FC-GPR, FC-TRS, LLP(I) and Form FC. Periodic returns such as the FLA return and Form APR carry a flat INR 7,500. RBI's circular of 30 Sep 2022 sets this matrix, and the route stays open for three years from the due date.

This page explains the formula, how RBI counts the delay, which forms fall in which row, the cap and how to pay. It also covers the ECB changes of 2026, the line between LSF and compounding, and worked numbers.

What is the late submission fee under FEMA?

The late submission fee is the amount RBI charges to accept a FEMA report filed after its due date. Regulation 5 of FEMA 395/2019-RB makes the filer liable to pay it for any delay in the reports listed in regulation 4. Paying it regularises the delay without compounding, if you file within three years.

FEMA requires each foreign investment, overseas investment and external borrowing to be reported to RBI within a fixed time. Form FC-GPR is due within 30 days of issuing shares to a non resident. Form FC-TRS is due within 60 days of a transfer. A late filing is a contravention of the reporting regulation.

RBI gives a cheaper way out than compounding for this one kind of breach. Regulation 5 of FEMA 395/2019-RB says the person filing the report "shall be liable for payment of late submission fee, as may be decided by the Reserve Bank, in consultation with the Central Government, for any delays in reporting." Regulation 11 of the Overseas Investment Regulations, 2022 does the same for overseas investment filings.

RBI introduced the LSF in stages. It started for foreign investment on 7 Nov 2017, for ECBs on 16 Jan 2019 and for overseas investment on 22 Aug 2022. A.P. (DIR Series) Circular No. 16 of 30 Sep 2022 then put all three on one matrix. That matrix applies to delayed filings made on or after 30 Sep 2022.

How is the LSF calculated?

The LSF has two forms. Flow or transactional returns pay INR 7,500 + (0.025% × A × n). Periodic returns that do not capture flows pay a flat INR 7,500. "A" is the amount involved in the delayed report. "n" is the delay in years, rounded up to the nearest month and expressed to two decimals.

Row	Type of return	Forms named in Circular No. 16 of 2022	LSF (INR)
1	Periodic, or returns that do not capture flows	Form ODI Part II or APR, FC-GPR (B), FLA return, Form OPI, evidence of investment, any other periodic return	7,500 flat
2	Flow or transactional returns	FC-GPR, FC-TRS, Form ESOP, Form LLP(I), Form LLP(II), Form CN, Form DI, Form InVi, Form ODI Part I, Form ODI Part III, Form FC, Form ECB, Form ECB 2, revised Form ECB, any other flow or non fund transaction return	7,500 + (0.025% × A × n)

The notes to the matrix add four rules:

1. The LSF is per return. A late FC-GPR and a late FC-TRS are two fees.
2. The LSF cannot exceed 100 percent of A. RBI rounds it up to the nearest hundred.
3. An LSF advice that stays unpaid for 30 days becomes void. RBI will not accept a payment after that.
4. If you come back later, the date of your new application becomes the reference date for n.

The variable part is small for most filings. A rate of 0.025 percent equals INR 2,500 a year for every INR 1,00,00,000 of A. So a one year delay on an INR 1,00,00,000 FC-GPR costs INR 10,000 in all.

The fixed part dominates small filings. Take a late FC-GPR for INR 10,00,000 filed one year late. It costs INR 7,500 + INR 250, which rounds up to INR 7,800.

How do you count the years of delay?

Count from the due date to the date you file. Round the delay up to the next whole month. Divide the months by 12 and express the result to two decimal places. Note (a) of the matrix sets this rule. It rounds the delay upwards to the nearest month and expresses n up to two decimal points.

The due date is the last day of the filing window. For an FC-GPR, that is 30 days from the date of issue under regulation 4(1). For an FC-TRS, it is 60 days from the transfer or from receipt or remittance of funds, whichever is earlier, under regulation 4(3).

Actual delay after the due date	Rounded up to	n (years)
10 days	1 month	0.08
3 months and 1 day	4 months	0.33
6 months and 16 days	7 months	0.58
Exactly 12 months	12 months	1.00
2 years, 2 months and 10 days	27 months	2.25
2 years, 11 months and 20 days	36 months	3.00

A single day of delay costs a full month in n. The fixed INR 7,500 applies from the first day. Filing one day late and filing eleven months late cost the same fixed amount. Only the small variable part grows.

File a complete form the first time. If the AD bank rejects a form, you file it again. The delay keeps running until the fresh filing.

Which forms attract the fixed fee and which the formula?

Flow returns attract the formula. These report money moving: FC-GPR, FC-TRS, LLP(I), LLP(II), Form CN, Form DI, Form InVi, Form FC and Form ECB 2. Periodic returns attract the flat INR 7,500. These include the FLA return, Form APR, Form OPI and evidence of investment. From 1 Apr 2026, Form ECB 1 also pays the flat fee.

Form	Due date	Rule	LSF type	Filed on or through
FC-GPR	30 days from issue of equity instruments	FEMA 395, regulation 4(1)	Formula	FIRMS, Single Master Form
FC-TRS	60 days from transfer or receipt or remittance of funds, whichever is earlier	FEMA 395, regulation 4(3)	Formula	FIRMS, Single Master Form
Form ESOP	30 days from issue	FEMA 395, regulation 4(4)	Formula	FIRMS, Single Master Form
Form LLP(I)	30 days from receipt of capital contribution	FEMA 395, regulation 4(6)	Formula	FIRMS, Single Master Form
Form LLP(II)	60 days from receipt of funds on disinvestment or transfer	FEMA 395, regulation 4(7)	Formula	FIRMS, Single Master Form
Form InVi	30 days from issue of units	FEMA 395, regulation 4(10)	Formula	FIRMS, Single Master Form
Form DI	30 days from allotment	FEMA 395, regulation 4(11)	Formula	FIRMS, Single Master Form
Form CN	30 days from issue or transfer of convertible notes	FEMA 395, regulation 4(12)	Formula	FIRMS, Single Master Form
FLA return	15 July each year	FEMA 395, regulation 4(2)	Flat 7,500	FLAIR portal
Form FC and ODI Part I and III	As set by regulation 10 of the OI Regulations	OI Regulations, 2022	Formula	Designated AD bank
Form APR	31 December each year	OI Regulations, regulation 10(4)	Flat 7,500	Designated AD bank
Form ECB 1	Before drawdown, to obtain the LRN	FEMA 3(R)(5)/2026-RB, Schedule I, paragraph 16	Flat 7,500 from 1 Apr 2026	Designated AD bank
Form ECB 2	Seven calendar days after month end	FEMA 3(R)(5)/2026-RB, Schedule I, paragraph 16	Formula, each return separate from 1 Apr 2026	Designated AD bank

The catch all wording matters. Row 2 also covers "any other return which captures flows". Row 1 covers "any other periodical reporting". So a form not named in the circular still falls into one row by its nature. Form DRR, filed by a domestic custodian within 30 days of the close of an issue, reports a flow. In our reading it sits in Row 2.

For the deadlines themselves, see our guide to FDI reporting requirements and the FC-GPR filing timeline.

What is the maximum delay for which LSF is available?

Three years from the due date. Note (f) of the 2022 matrix keeps the LSF facility open "up to three years from the due date". For overseas investment, the proviso to regulation 11(1) of the OI Regulations, 2022 says the same. Past three years, only compounding remains.

Circular No. 22 of 4 Jan 2023 built this into FIRMS. The system flags the delay on each Single Master Form. Where the delay is up to three years, the AD bank approves the form subject to the LSF. Where it is over three years, the AD bank approves the form subject to compounding. You then apply to RBI to compound.

Older overseas investment delays had a separate window. Regulation 11(2) of the OI Regulations covered delays under the earlier overseas investment regulations, such as FEMA 120/2004-RB. It gave them three years from the Gazette date of 22 Aug 2022. That window closed in August 2025. Those delays now need compounding.

Track the three year date for every late form. A form due on 9 Feb 2024 can still go with LSF until 9 Feb 2027. From the next day, it needs a compounding application, with its own fee and a longer process.

Is there a cap on the LSF?

Yes. Note (d) of the matrix limits the LSF to "100 per cent of 'A'". It also rounds the LSF upwards to the nearest hundred. The cap matters only when the amount involved is very small. For most filings, the formula stays far below A.

The cap bites on tiny filings. A foreign co founder who subscribes INR 5,000 of shares at incorporation creates an FC-GPR with A of INR 5,000. The formula gives a little over INR 7,500. The cap brings the LSF down to INR 5,000.

Rounding always goes up. An LSF of INR 9,675 becomes INR 9,700. An LSF of INR 1,48,125 becomes INR 1,48,200.

How do you pay the LSF on FIRMS?

You do not pay at the time of filing. You file the late form on FIRMS. The AD bank verifies it within five working days. The system computes the LSF and emails you and the RBI Regional Office with the amount and the time to pay. You pay within 30 days. The Regional Office then updates the status.

A.P. (DIR Series) Circular No. 22 of 4 Jan 2023 set out this flow for the Single Master Form. It says the AD bank will "advise the Late Submission Fee (LSF) to the applicants", with the system computing the amount. It adds that "Once the LSF amount is realised, the concerned RO will update the status in the FIRMS portal".

The steps in order:

1. Log in to FIRMS as the entity's business user and open the Single Master Form.
2. Fill the late form, for example FC-GPR, with the actual dates of receipt and issue.
3. Upload the documents, including the FIRC, KYC, valuation report and company secretary certificate.
4. Submit. FIRMS timestamps the form and sends an automated email.
5. Wait for the AD bank to verify it, within five working days.
6. Read the LSF email. It gives the amount, the Regional Office and the deadline.
7. Pay the LSF within 30 days of the advice, as the email instructs.
8. Keep the payment proof and watch for the status update and the approval email.

The payment mode depends on the type of filing. For ECB returns, Circular No. 25 of 30 Mar 2026 makes the LSF payable at the Regional Office by NEFT or RTGS. For overseas investment, paragraph 18(3) of the Overseas Investment Directions, 2022 provides for a demand draft. The draft is in favour of "Reserve Bank of India", payable at the Regional Office for your UIN prefix.

For foreign investment filings, Circular No. 22 of 2023 names no payment mode. The FIRMS email gives the amount, the Regional Office and the deadline. Follow the payment steps in that email and in the FIRMS manual at firms.rbi.org.in, which prevails over the circular where the two differ.

For the FLA return, RBI's FLA FAQ, updated 1 Jul 2026, points you to the Foreign Exchange Department of the Regional Office that covers your registered office.

Do not miss the 30 day window. Note (e) says an unpaid advice becomes "null and void", and RBI will not accept a late payment. A fresh application then resets the reference date for n, so the fee grows.

How does LSF work for ECB returns from 1 Apr 2026?

From 1 Apr 2026, Circular No. 25 of 30 Mar 2026 changed three things about the fee. Each late Form ECB 2 under an LRN is a separate instance for the fixed INR 7,500. Form ECB 1 and revised ECB 1 count as returns that do not capture flows, so they pay the flat fee. The LSF is payable by NEFT or RTGS. The circular also sets two duties for the AD bank.

The ECB framework itself changed earlier in 2026. FEMA 3(R)(5)/2026-RB of 9 Feb 2026 amended the Borrowing and Lending Regulations, 2018 and restated the ECB framework in a new Schedule I. The Gazette published it on 16 Feb 2026. A.P. (DIR Series) Circular No. 23 of 18 Feb 2026 then substituted new formats for Form ECB 1 and Form ECB 2.

Circular No. 25 of 30 Mar 2026 changed how the LSF works on those returns:

1. Separate instances. Under paragraph 2(ii), each late Form ECB 2 under an LRN is "a separate instance" for the fixed component. Under note (c) of 2022, each delayed LRN counted as one instance, so all late ECB 2 returns under one LRN carried one fixed component.
2. Form ECB 1 on the flat fee. Paragraph 2(i) treats Form ECB 1 and revised ECB 1 as returns that do not capture flows. In the 2022 matrix, Form ECB sat in the formula row.
3. Payment by NEFT or RTGS. Paragraph 2(iv) makes the LSF payable at the Regional Office by NEFT or RTGS, after RBI emails an acknowledgment of the return with instructions.
4. Bank timelines. The designated AD bank must submit a complete return within seven calendar days of receiving it. It must also monitor whether delayed filers pay the LSF.

"A" for a Form ECB 2 is the gross inflow or outflow for the month, including interest and other charges, whichever is more. That rule from note (c) of 2022 still applies.

The practical effect is a higher bill for a borrower who stops filing for months. Six missed monthly returns under one LRN now mean six fixed components of INR 7,500 each, or INR 45,000 before the variable parts. Our page on the ECB loan from a foreign parent covers the reporting cycle.

If the ECB lender takes security, our guide to CHG-1 for registering a charge on loans explains the separate filing with the Registrar.

How does LSF work for overseas investment forms?

The same matrix applies through paragraph 18 of the Overseas Investment Directions, 2022. Form FC, Form ODI Part I and Part III use the formula. Form APR, Form OPI, the FLA return and evidence of investment pay a flat INR 7,500. You file through your designated AD bank and pay at the Regional Office for your UIN prefix.

Regulation 12 of the OI Regulations adds a hard stop. Until the delay is regularised, you cannot make any further financial commitment, fund based or non fund based, towards that foreign entity. You also cannot transfer the investment. So a late APR can hold up a capital call to your overseas subsidiary.

Each late APR is a separate return. Two missed years for one UIN mean two fees, or INR 15,000. Our APR guide has the due dates and the three year cut offs.

Since 1 Apr 2026, A.P. (DIR Series) Circular No. 02 of 2026 routes overseas investment references to seven RBI Regional Offices through PRAVAAH. The UIN prefix decides the office.

What is the difference between LSF and compounding?

LSF regularises a reporting delay of up to three years for a fee set by formula. Compounding settles any compoundable FEMA contravention, including a reporting delay beyond three years, for an amount RBI decides. Compounding needs an application, an INR 10,000 fee plus GST, and an order. LSF needs only the late filing and the payment.

Point	Late submission fee	Compounding
What it covers	Delay in a FEMA report	Any compoundable contravention, including late allotment, refund or pricing breaches
Time limit	Up to three years from the due date	Used after the three year window, or for other breaches
Legal basis	Regulation 5 of FEMA 395/2019-RB; regulation 11 of the OI Regulations	Section 15 of FEMA, 1999; Foreign Exchange (Compounding Proceedings) Rules, 2024
Who fixes the amount	The matrix, computed by FIRMS or the AD bank	RBI, under its compounding directions
Application fee (INR)	None	10,000 plus GST (18% per RBI FAQ of 1 Oct 2024)
Payment deadline	30 days from the LSF advice	15 days from the compounding order
Typical cost	INR 7,500 plus a small variable part	Usually higher, and set case by case

RBI's compounding FAQ, updated 1 Oct 2024, sets the application fee and the 15 day payment rule. It says an unpaid compounded amount means the application is treated as never made and the case goes to the Directorate of Enforcement.

Use LSF whenever you can. It is faster and cheaper. Our FEMA compounding guide covers the longer route. For what RBI has charged on late FC-GPR cases, see our note on RBI compounding orders for late FC-GPR.

What happens if you do not pay the LSF?

The advice lapses after 30 days and the delay stays unregularised. Note (g) of the matrix covers a person who neither files on time nor files with the LSF. That person is "liable for penal action" under FEMA, 1999. In practice, the form stays unapproved and later filings get stuck.

An unapproved FC-GPR causes trouble later. The company cannot show RBI acknowledgment for those shares. A later FC-TRS on the same shares, a downstream investment or a due diligence will expose the gap. For overseas investment, regulation 12 blocks further commitments.

If the advice lapsed, apply again. The new application date becomes the reference date for n. Pay the fresh advice within 30 days. If the three year window has closed meanwhile, the route moves to compounding.

Section 13 of FEMA, 1999 sets the penalty on adjudication. It can reach three times the sum involved where the amount is quantifiable, or INR 2,00,000 where it is not. A continuing contravention can add up to INR 5,000 for each day after the first.

If you want outside help with a lapsed advice, our guide to the best FEMA consultants in India explains how foreign founders should choose one.

Does LSF cover other FEMA breaches such as late allotment?

No. The LSF covers only the delay in filing a report. Other breaches need compounding. Examples are issuing shares more than 60 days after receiving the money, a late refund, issuing below fair value or breaching a sector cap. Paying an LSF on the FC-GPR does not cure them.

Regulation 3.1 of FEMA 395/2019-RB requires shares to be issued within 60 days of receipt of the money. If the company cannot issue them, it must refund the money within the next 15 days. A company that issued shares on day 75 and filed FC-GPR on day 110 has two problems. The FC-GPR delay goes through LSF. The late issue goes through compounding.

The AD bank and RBI see both in the same form. The FC-GPR records the date of receipt and the date of issue. If the gap exceeds 60 days, expect the bank to flag it. Our guide to FC-GPR compounding explains how to handle the late issue.

If your file has several late forms, our FEMA compliance team maps each delay to LSF or compounding before you file.

What changed in 2026

Point	Old rule	New rule	Date	Instrument
Late Form ECB 2 returns under one LRN	One fixed component per LRN (note (c), 2022)	Each late return a separate instance	1 Apr 2026	A.P. (DIR Series) Circular No. 25 of 30 Mar 2026
Form ECB 1 and revised ECB 1	Formula row	Flat INR 7,500 as returns that do not capture flows	1 Apr 2026	Circular No. 25 of 30 Mar 2026
Payment of ECB LSF	Advice from RBI	NEFT or RTGS to the Regional Office after RBI's email	1 Apr 2026	Circular No. 25 of 30 Mar 2026
ECB return formats	Form ECB and Form ECB 2	New Form ECB 1 and Form ECB 2 formats	18 Feb 2026	Circular No. 23 of 18 Feb 2026
ECB framework	Earlier ECB framework	New ECB framework, LRN before drawdown	9 Feb 2026	FEMA 3(R)(5)/2026-RB
Overseas investment references	RBI Central Office	Seven Regional Offices through PRAVAAH	1 Apr 2026	A.P. (DIR Series) Circular No. 02 of 1 Apr 2026
LSF for delays under FEMA 120/2004-RB	Open for three years from 22 Aug 2022	Window closed	August 2025	OI Regulations, regulation 11(2)

The matrix for foreign investment forms on FIRMS is the 2022 matrix. FEMA 395/2019-RB, amended up to 13 Jun 2026, keeps regulation 5 unchanged. Circular No. 25 of 30 Mar 2026 points to Parts V and XIII of the Master Direction on Reporting under FEMA for the LSF directions. RBI replaced that Master Direction on 1 Oct 2026 without marking the changes. Part XIII is the operative text, so read it on the RBI site before you finalise a fee.

What has happened since 12 Mar 2026

This page went live on 12 Mar 2026. Since then:

1. 30 Mar 2026. RBI issued Circular No. 25 on ECB returns, effective 1 Apr 2026, with the three LSF changes above.
2. 1 Apr 2026. Circular No. 02 of 2026 moved overseas investment references to seven Regional Offices.
3. 13 Jun 2026. FEMA 395(4)/2026-RB amended FEMA 395/2019-RB. It substituted Schedules III and XI and the LEC (IFI) item, and left regulation 5 alone.
4. 1 Apr to 1 Oct 2026. RBI updated the Master Direction on Reporting under FEMA on 1 Apr, 24 Jun, 23 Sep and 1 Oct 2026.

Worked example

Late FC-GPR for a foreign parent's investment

A US parent remits INR 1,50,00,000 to its Indian subsidiary. The company issues shares on 10 Jan 2026. The FC-GPR is due on 9 Feb 2026. The company files it on 25 Aug 2026.

Step	Working	Result
Delay after the due date	9 Feb 2026 to 25 Aug 2026	6 months and 16 days
Rounded up	Next whole month	7 months
n	7 ÷ 12, to two decimals	0.58
Variable part	0.025% × INR 1,50,00,000 × 0.58	INR 2,175
LSF before rounding	INR 7,500 + INR 2,175	INR 9,675
Cap check	100% of A is INR 1,50,00,000	Not reached
LSF payable	Rounded up to the nearest hundred	INR 9,700

The company pays INR 9,700 within 30 days of the advice. The issue on 10 Jan 2026 must also have been within 60 days of receiving the money. If it was not, that breach needs compounding.

Late FC-TRS near the three year limit

A resident sells shares to a Singapore investor for INR 25,00,00,000. The funds arrive on 1 Jun 2024. The FC-TRS is due on 31 Jul 2024. The parties file it on 10 Oct 2026.

Step	Working	Result
Delay after the due date	31 Jul 2024 to 10 Oct 2026	2 years, 2 months and 10 days
Rounded up	Next whole month	27 months
n	27 ÷ 12	2.25
Variable part	0.025% × INR 25,00,00,000 × 2.25	INR 1,40,625
LSF before rounding	INR 7,500 + INR 1,40,625	INR 1,48,125
LSF payable	Rounded up to the nearest hundred	INR 1,48,200

The LSF window for this FC-TRS closes on 31 Jul 2027. A filing after that would need compounding. Our page on share transfer between a resident and a non resident covers the FC-TRS itself.

The cap and the fixed fee

Two short cases show the other rules:

1. Subscriber shares. A foreign co founder subscribes INR 5,000 at incorporation. The FC-GPR goes in 1 year, 5 months and 3 days late. The delay rounds up to 18 months, so n is 1.50. The formula gives INR 7,500 + INR 1.88, or INR 7,501.88. The cap limits the LSF to 100 percent of A, so the LSF is INR 5,000.
2. Late FLA return. An Indian company with FDI files its FLA return eight months after 15 July. It pays a flat INR 7,500, whatever the size of its foreign liabilities.

Common mistakes

1. Waiting to fix a late form. The fixed fee is the same from day one, and the three year window keeps shrinking. Fix: file the late form as soon as you find the gap.
2. Missing the 30 day payment window. The advice lapses and n is recomputed from your new application. Fix: diarise the deadline on the day the LSF email arrives and pay the same week.
3. Treating the LSF as the cure for late allotment. The LSF covers only the reporting delay. Fix: check the 60 day issue rule and the 15 day refund rule, and compound any breach.
4. Counting the delay from the wrong date. The clock starts at the due date, not the date of receipt or issue. Fix: compute the due date first, then count the delay to your filing date.
5. Forgetting the rounding. A delay of 3 months and 1 day counts as 4 months. Fix: always round up to the next whole month before you divide by 12.
6. Assuming one fee for many ECB 2 returns. From 1 Apr 2026, each late return under an LRN carries its own fixed component. Fix: file every monthly ECB 2 within seven calendar days after month end.
7. Letting the three year window pass. After it, only compounding remains. Fix: list every late form with its due date and its three year cut off.
8. Filing an incomplete form. A rejected form must be refiled, and the delay keeps running. Fix: upload every document the Single Master Form asks for before you submit.
9. Leaving a late APR open. Regulation 12 blocks further commitments to the overseas entity. Fix: clear late APRs before any capital call or guarantee to that entity.

Checklist

1. List every FEMA report the company has filed or should have filed, with its due date.
2. Compare the due date with the filing date to find each delay.
3. Mark any delay over three years for compounding instead of LSF.
4. Check the FC-GPR dates for the 60 day issue rule and the 15 day refund rule.
5. Compute the expected LSF for each late form with the matrix.
6. File each late form on FIRMS, FLAIR or through the AD bank, with full documents.
7. Respond to any AD bank query within its deadline.
8. Pay each LSF advice within 30 days, in the mode the advice gives.
9. Save the payment proof and the approval email in the FEMA file.
10. Prepare a compounding application for any delay or breach the LSF does not cover.
11. Set up a calendar for FC-GPR, FC-TRS, FLA, APR and ECB 2 dates so the gap does not recur.

Frequently Asked Questions

What is the late submission fee under FEMA?+

It is the fee RBI charges to accept a FEMA report filed after its due date. Regulation 5 of FEMA 395/2019-RB provides for it for foreign investment reports. Regulation 11 of the Overseas Investment Regulations, 2022 does so for overseas investment. A.P. (DIR Series) Circular No. 16 of 30 Sep 2022 sets the amounts.

What is the LSF formula?+

Flow returns such as FC-GPR, FC-TRS, LLP(I), Form FC and Form ECB 2 pay INR 7,500 + (0.025% × A × n). A is the amount involved and n is the delay in years. Periodic returns such as the FLA return and Form APR pay a flat INR 7,500.

How is n calculated in the LSF formula?+

n is the delay from the due date to the filing date, rounded up to the nearest month and expressed in years to two decimals. A delay of 6 months and 16 days becomes 7 months, so n is 0.58. Note (a) of Circular No. 16 of 2022 sets this rule.

What is the late submission fee for a late FC-GPR?+

INR 7,500 plus 0.025 percent of the amount reported for each year of delay. Take an issue of INR 1,50,00,000 filed 6 months and 16 days late. Here n is 0.58, and the LSF is INR 9,675, rounded up to INR 9,700. The FC-GPR is due within 30 days of issue under regulation 4(1) of FEMA 395/2019-RB.

Is there a maximum late submission fee?+

Yes. Note (d) of Circular No. 16 of 2022 caps the LSF at 100 percent of the amount involved, rounded up to the nearest hundred. The cap matters only for very small filings. An FC-GPR for INR 5,000 of subscriber shares is an example, because the formula exceeds the amount.

How many years of delay can be regularised with LSF?+

Up to three years from the due date. Note (f) of the 2022 matrix and the proviso to regulation 11(1) of the Overseas Investment Regulations, 2022 set this limit. For a longer delay, the AD bank approves the form subject to compounding. You then apply to RBI under the Compounding Proceedings Rules, 2024.

How do I pay the LSF for a form filed on FIRMS?+

File the late form on FIRMS. After the AD bank verifies it, the system emails you and the RBI Regional Office with the LSF amount and the deadline. Pay as the email instructs within 30 days. The Regional Office then updates FIRMS, under A.P. (DIR Series) Circular No. 22 of 4 Jan 2023.

What happens if I pay the LSF after 30 days?+

RBI will not accept it. Note (e) of Circular No. 16 of 2022 says an unpaid advice becomes null and void after 30 days. You must apply again, and the date of the new application becomes the reference date for n. If the three year window has closed by then, you need compounding.

Is the late submission fee for the FLA return fixed?+

Yes. The FLA return is in Row 1 of the 2022 matrix. A late FLA return costs a flat INR 7,500, however large the company's foreign liabilities. The return is due by 15 July under regulation 4(2) of FEMA 395/2019-RB. RBI's FLA FAQ tells you to contact your Regional Office to pay.

What is the late submission fee for Form ECB 2 returns?+

INR 7,500 + (0.025% × A × n) for each late return, where A is the month's gross inflow or outflow including interest, whichever is more. From 1 Apr 2026, Circular No. 25 of 30 Mar 2026 treats each late ECB 2 under an LRN as a separate instance. You pay by NEFT or RTGS.

Did the LSF for Form ECB change in 2026?+

Yes. From 1 Apr 2026, A.P. (DIR Series) Circular No. 25 of 30 Mar 2026 treats Form ECB 1 and revised ECB 1 as returns that do not capture flows. A late Form ECB 1 therefore pays the flat INR 7,500. Under the 2022 matrix, Form ECB sat in the formula row.

What is the late submission fee for a late APR?+

A flat INR 7,500 per APR under paragraph 18 of the Overseas Investment Directions, 2022. Each late year is a separate return. Until you regularise the delay, regulation 12 of the OI Regulations bars further financial commitment to that foreign entity. It also bars transfer of the investment.

Is the late submission fee the same as compounding?+

No. The LSF is a fixed formula fee for a reporting delay of up to three years. Compounding settles any compoundable FEMA contravention for an amount RBI decides, under section 15 of FEMA, 1999. It needs an application with an INR 10,000 fee plus GST, and payment within 15 days of the order.

Does paying LSF cure a late allotment of shares?+

No. The LSF covers only the late FC-GPR. Issuing shares more than 60 days after receiving the money breaches regulation 3.1 of FEMA 395/2019-RB, and that needs compounding. A late refund beyond the next 15 days is also a separate breach.

Who pays the late submission fee for an FC-TRS?+

The person responsible for filing the FC-TRS pays it. Regulation 4(3) of FEMA 395/2019-RB puts the filing on the resident transferor or transferee. Where a non resident holds on a non repatriation basis, it falls on that holder. The parties can agree in the share purchase agreement who bears the cost.

Sources

• Reserve Bank of India, A.P. (DIR Series) Circular No. 16, Late Submission Fee for reporting delays under FEMA, 30 Sep 2022, https://rbi.org.in/Scripts/NotificationUser.aspx?Id=12393&Mode=0
• Reserve Bank of India, A.P. (DIR Series) Circular No. 22, Rationalisation of reporting in Single Master Form on FIRMS, 4 Jan 2023, https://www.rbi.org.in/scripts/NotificationUser.aspx?Id=12433&Mode=0
• Reserve Bank of India, A.P. (DIR Series) Circular No. 25, Returns pertaining to External Commercial Borrowing, 30 Mar 2026, https://rbi.org.in/Scripts/BS_CircularIndexDisplay.aspx?Id=13345
• Reserve Bank of India, A.P. (DIR Series) Circular No. 23, Returns pertaining to External Commercial Borrowing, 18 Feb 2026, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13308&Mode=0
• Reserve Bank of India, Foreign Exchange Management (Mode of Payment and Reporting of Non Debt Instruments) Regulations, 2019, FEMA 395/2019-RB, amended up to 13 Jun 2026, https://rbi.org.in/scripts/BS_FemaNotifications.aspx?Id=11723
• Reserve Bank of India, Foreign Exchange Management (Overseas Investment) Regulations, 2022, FEMA 400/2022-RB, 22 Aug 2022, https://rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=12380
• Reserve Bank of India, Foreign Exchange Management (Overseas Investment) Directions, 2022, paragraph 18, https://www.rbi.org.in/scripts/BS_ViewMasDirections.aspx?id=12381
• Reserve Bank of India, Master Direction, Reporting under Foreign Exchange Management Act, 1999, updated as on 1 Oct 2026, https://rbi.org.in/Scripts/BS_ViewMasDirections.aspx?id=10202
• Reserve Bank of India, Foreign Exchange Management (Borrowing and Lending) (First Amendment) Regulations, 2026, Notification No. FEMA 3(R)(5)/2026-RB, 9 Feb 2026, Schedule I, paragraph 16, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13306&Mode=0
• Reserve Bank of India, FAQs on the FLA return, updated 1 Jul 2026, https://www.rbi.org.in/scripts/FAQView.aspx?Id=95
• Reserve Bank of India, FAQs on Compounding of Contraventions under FEMA, 1999, updated 1 Oct 2024, https://www.rbi.org.in/commonman/english/scripts/FAQs.aspx?Id=835
• Government of India, Foreign Exchange Management Act, 1999 (Act 42 of 1999), sections 13 and 15, https://www.indiacode.nic.in/bitstream/123456789/1988/1/A1999_42.pdf