GENERAL
MIS Report Format for an Indian Subsidiary of a Foreign Parent (2026)
What an MIS report is, the types companies use, and the monthly pack an Indian subsidiary sends its foreign parent, with KPI formulas, a ten day close, India compliance lines and a cost plus markup check.
General

Written by Nihal Srivastava, Krystal7 Consultants. Last updated 1 October 2026.
An MIS report (management information system report) is an internal report that gives managers the figures they need to decide. It compares results with budget and shows cash, receivables, headcount, KPIs and exceptions. No Indian law prescribes its format. For an Indian subsidiary, the MIS is the monthly pack it sends its foreign parent, which in our practice closes by working day 10. Its India lines track TDS paid by the 7th, GSTR-1 by the 11th, GSTR-3B by the 20th, FEMA filings and the markup.
This page defines the MIS report and its types, then sets out the monthly pack we build for foreign owned subsidiaries in India. It gives a template, KPI formulas, a ten day close calendar and a worked example for a 60 person development centre. INR 1 lakh is INR 1,00,000 (100,000) and INR 1 crore is INR 1,00,00,000 (10 million).
What is an MIS report?
An MIS report is a structured summary of business data that managers receive on a fixed cycle. MIS stands for management information system. The report turns ledger, payroll, sales and operating data into a short set of figures, comparisons and comments. A manager should be able to act on it within the month.
Three features separate an MIS report from a ledger printout:
- It compares. Every figure sits next to a budget, a forecast, a prior period or a target.
- It explains. Each material variance carries a cause, an owner and an action.
- It looks forward. A good pack ends with the updated forecast and the decisions the reader must take.
In a foreign owned subsidiary, the main reader is the parent. Group finance needs it for consolidation, FP&A for the forecast and group tax for transfer pricing.
No law prescribes the format. Section 128 of the Companies Act, 2013 requires books of account that give a true and fair view. It requires them on the accrual basis and by double entry. The MIS draws on those books but is not one of them, so the parent should fix its layout in writing.
| Question | Short answer |
|---|---|
| Full form | Management information system report |
| Who prepares it | The finance team or an outsourced finance provider |
| Who reads it | Board, managing director, department heads, the parent's finance teams, sometimes lenders |
| How often | Monthly for the full pack; weekly for cash |
| Legal format | None; the books behind it must meet section 128 of the Companies Act, 2013 |
| Audited | No; the statutory auditor audits the annual financial statements |
What types of MIS report do companies use?
Companies group MIS reports by function (finance, sales, people, operations, compliance) and by trigger (scheduled, exception and on demand). A subsidiary that reports to a foreign parent needs the financial, cash, receivables, headcount and compliance reports every month. It adds exception reports when a set limit breaks.
| Type | What it shows | Usual cycle |
|---|---|---|
| Financial MIS | Income statement, balance sheet and cash flow against budget | Monthly |
| Flash report | Headline revenue, cost, cash and headcount before the full close | Monthly, early in the close |
| Cash report | Bank balances and a 13 week cash forecast | Weekly |
| Receivables and payables ageing | Invoices by age band, with MSME suppliers shown apart | Monthly |
| Sales MIS | Orders, billing, pipeline, customer mix | Weekly or monthly |
| Cost centre or project MIS | Cost by team or project against budget | Monthly |
| Headcount and payroll MIS | Joiners, leavers, open roles, cost per head | Monthly |
| Compliance MIS | Status of tax, FEMA, company law and labour filings | Monthly |
| Exception report | Items outside a set limit, such as a cost line 10% over budget | When triggered |
| Board pack | Quarterly results, KPIs, risks and decisions sought | Quarterly |
What should an Indian subsidiary send its foreign parent each month?
Send one pack with twelve fixed sections. It opens with a one page summary. The core statements, cash forecast, headcount and KPIs follow. Then come the transfer pricing check, intercompany balances, capital spend, the India compliance block, open issues and appendices. Keep the order fixed so the parent can compare months at a glance.
| No. | Section | Contents | Owner |
|---|---|---|---|
| 1 | One page summary | Headline figures, markup, cash, headcount, compliance status, issues | Finance head |
| 2 | Income statement | Month and year to date against budget, forecast and prior year | Accountant |
| 3 | Balance sheet | Closing balances, working capital, provisions | Accountant |
| 4 | Cash flow and forecast | Cash movement, 13 week forecast, funding needed | Finance head |
| 5 | Headcount and payroll | Opening, joiners, leavers, closing, open roles, cost by grade | HR and payroll |
| 6 | KPIs | The agreed KPI set with a 13 month trend | Finance head |
| 7 | Transfer pricing check | Cost base, markup billed and earned, true up to invoice | Finance head with group tax |
| 8 | Intercompany | Balances with each group entity, matched or explained | Accountant |
| 9 | Capital spend | Additions against the capex budget | Accountant |
| 10 | India compliance status | GST, TDS, advance tax, FEMA, company law and payroll items with evidence | Compliance lead |
| 11 | Issues and decisions | Risks, audit points, approvals the parent must give | Managing director |
| 12 | Appendices | Trial balance, GAAP bridge, group pack mapping, reconciliations | Accountant |
Write the pack's rules into a short reporting manual that both finance teams sign. It fixes the definitions, the exchange rate source, the commentary threshold and the calendar. Our guide to a virtual CFO for a foreign subsidiary covers who owns each step when finance is outsourced.
What goes on the one page summary?
The one page summary answers five questions from the parent. Every other section of the pack supports those answers. It fits on one screen and keeps the same layout every month. The parent's CFO should be able to brief the group from this page alone.
- Did we hit budget?
- Is the markup right?
- How much cash do we hold?
- Are we staffed to plan?
- Is anything overdue with a regulator?
| Block | What it shows | Format tip |
|---|---|---|
| Headline numbers | Revenue, operating cost, operating profit and profit before tax against budget | Six to eight lines, in INR and parent currency |
| Markup | Markup earned and billed on actual cost, true up to invoice | Percent and INR |
| Cash | Closing cash, months of cost covered, funding request | Refer to the 13 week forecast |
| People | Headcount against plan, joiners, leavers, open roles | Numbers, not names |
| Compliance | Red, amber or green for GST, TDS, FEMA, company law and payroll | Red is overdue; amber is due within seven days |
| Issues and asks | Items that need the parent, each with a date | No more than five lines |
The worked example below fills this layout with illustrative numbers for an invented company.
Which KPIs belong in the pack, and how are they calculated?
Pick KPIs the parent can act on, and define each one once in a KPI dictionary. A cost plus development centre needs markup on total cost, cost per FTE, personnel cost ratio, attrition, utilisation, DSO, cash runway and budget variance. A sales subsidiary adds revenue growth, gross margin and customer concentration.
| KPI | Formula | Watch point |
|---|---|---|
| Operating cost (cost base) | Sum of operating expenses as the service agreement defines them | Agree the exclusions once, in writing |
| Markup on total cost | (Operating revenue − operating cost) ÷ operating cost | Compare with the agreed rate, the benchmark and the 15.5% safe harbour |
| EBITDA | Profit before tax + finance costs + depreciation and amortisation | State whether other income is inside |
| Gross margin (sales subsidiary) | (Revenue − cost of sales) ÷ revenue | Define cost of sales once |
| Cost per FTE per month | Total operating cost ÷ average FTE, where average FTE = (opening + closing) ÷ 2 | Count contractors apart |
| Personnel cost ratio | Personnel cost ÷ total operating cost | Include employer PF, gratuity and leave |
| Annualised attrition | (Leavers in the month ÷ average headcount) × 12 | Show voluntary leavers apart |
| Utilisation | Productive hours ÷ available hours | Agree what counts as productive |
| Budget variance | Actual − budget; percent = (actual − budget) ÷ budget | Label it favourable or adverse |
| DSO | Trade receivables ÷ revenue for the period × days in the period | Split intercompany and third party |
| Cash runway (months) | Cash and bank ÷ average monthly net cash outflow for three months | Include committed capex |
| Unbilled true up | Revenue at the agreed markup − amount invoiced | Invoice at least each quarter |
| Export invoices near the FEMA limit | Unrealised export invoices older than 180 days | The legal limit is nine months from the invoice date, or twelve if invoiced or settled in INR |
| Unutilised input tax credit | Closing balance of the electronic credit ledger | Track refund claims beside it |
| Statutory on time rate | Items paid or filed by the due date ÷ items due in the month | Target 100% |
Keep a 13 month trend for each KPI, so the parent sees the same month last year. Do not change a definition in the middle of a year. If you must, restate the earlier months and note the change on the summary.
Which India specific compliance items belong in the pack?
Include every item with a statutory date that the parent cannot see from abroad. That means GST returns, TDS deposits and quarterly statements, advance tax, remittance forms, transfer pricing filings, FEMA reports, company law filings and payroll dues. Show each with its due date, its status and an evidence reference, such as a challan or acknowledgement number.
The block also serves the audit. CARO 2020 clause 3(vii) asks the statutory auditor whether the company deposited undisputed statutory dues regularly. A monthly record with challan numbers answers that question.
The first table covers GST and income tax. The Income Tax Act, 2025 and the Income Tax Rules, 2026 apply from 1 Apr 2026, so the TDS forms carry new numbers. Our guide to TDS on payments to non residents covers Form 144 in detail.
| Item | Law or source | Due date | Evidence in the pack |
|---|---|---|---|
| GSTR-1 | GSTN return FAQs | 11th of the next month (monthly filers); 13th after the quarter (QRMP) | ARN |
| GSTR-3B | GSTN return FAQs | 20th of the next month (monthly filers); 22nd or 24th after the quarter, by state (QRMP) | ARN, cash paid |
| Input tax credit reconciliation | Books against GSTR-2B | Before GSTR-3B | Unmatched credit |
| LUT for zero rated exports | Form GST RFD-11 | Before the first export invoice of the financial year | ARN |
| GSTR-9 annual return | Section 44, CGST Act, 2017; GSTN FAQs | 31 December after the year end; the portal opens it only after every GSTR-1 and GSTR-3B for the year is filed | ARN, or readiness before then |
| TDS deposit | Rule 218(2), Income Tax Rules, 2026 | 7th of the next month; 30 April for March | Challan number |
| Form 138 (salary), Form 140 (residents), Form 144 (non residents) | Section 397(3)(b); rule 219 | 31 Jul, 31 Oct, 31 Jan and 31 May | Token number |
| Form 131 TDS certificates | Rule 215(1) | 15 days after the Form 140 or Form 144 due date | Issued |
| Forms 145 and 146 | Section 397(3)(d); rule 220 | Before each remittance abroad | Acknowledgement |
| Advance tax | Section 408 | 15% by 15 Jun, 45% by 15 Sep, 75% by 15 Dec, 100% by 15 Mar | Challan number |
| Transfer pricing report | Form 48; section 172; rule 85 | One month before the return due date | Study status |
For FY 2025-26, returns still use the Income Tax Act, 1961 forms. A company with international transactions files its tax audit report and Form 3CEB by 31 Oct 2026 and its return by 30 Nov 2026. Other audited companies file the tax audit report by 21 Oct 2026 and the return by 21 Nov 2026, under CBDT Circular No. 07/2026 of 28 Sep 2026.
The second table covers FEMA, company law and payroll.
| Item | Law or source | Due date or limit | Evidence in the pack |
|---|---|---|---|
| Shares against parent funding | Regulation 3.1, FEMA 395/2019-RB | Issue within 60 days of receipt; refund within the next 15 days | Days since receipt |
| FC-GPR | Regulation 4(1), FEMA 395/2019-RB | 30 days from the date of issue | FIRMS acknowledgement |
| FC-TRS | Regulation 4(3), FEMA 395/2019-RB | 60 days | FIRMS acknowledgement |
| FLA return | RBI FAQ on the FLA return | 15 July each year | FLAIR acknowledgement |
| Form ECB 2 | Schedule I, paragraph 16(1)(c), as substituted by FEMA 3(R)(5)/2026-RB | 7 calendar days after the end of a month with a drawdown or debt servicing | Bank acknowledgement |
| Export realisation | Regulation 5(1)(a), FEMA 23(R)/2026-RB, as amended by FEMA 23(R)/(1)/2026-RB; from 1 Oct 2026 | Nine months from the invoice date; twelve if invoiced or settled in INR; the AD bank may extend | Invoices over 180 days |
| EDF for services | Regulation 3(2), FEMA 23(R)/2026-RB | 30 days from the end of the invoice month | EDF reference |
| Board meetings | Section 173(1), Companies Act, 2013 | Four a year, with no more than 120 days between two meetings | Last and next date |
| AGM | Section 96 | Within six months of the year end (nine months for the first AGM) | Date held |
| AOC-4 and MGT-7 | Sections 137 and 92(4) | 30 and 60 days after the AGM | SRN |
| DPT-3 | Rule 16, Companies (Acceptance of Deposits) Rules, 2014 | 30 June | SRN |
| PAS-3 | Section 39(4); rule 12 | 30 days after a rights allotment | SRN |
| MSME Form 1 | Paragraph 3, Specified Companies Order, 2019 (S.O. 368(E)), as amended by S.O. 2751(E) of 15 Jul 2024 | Half yearly: 31 October for April to September, 30 April for October to March; only if a micro or small supplier is unpaid beyond 45 days | SRN, or no dues over 45 days |
| DIR-3 KYC Web | Rule 12A, as substituted by G.S.R. 943(E) | 30 June after every third financial year; next by 30 Jun 2028 for directors whose KYC is current | Status per director |
| PF and ESI | Code on Social Security, 2020; EPF Scheme, 2026 and ESIC regulations | Monthly; we work to the 15th of the next month and check each scheme's current text with EPFO and ESIC | ECR and challan |
| EPF wage ceiling | S.O. 5109(E) | INR 25,000 from 17 Sep 2026 | Payroll updated |
The export rows changed on 1 Oct 2026. The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 replaced the 2015 regulations and SOFTEX on that date. Before they started, FEMA 23(R)/(1)/2026-RB of 22 Sep 2026 cut their realisation period from fifteen months to nine. For INR invoicing or settlement, it cut eighteen months to twelve. On our reading, an invoice raised before 1 Oct 2026 stays under the 2015 regulations. Their limit has also been nine months since FEMA 23(R)/(8)/2026-RB of 5 Jun 2026.
Use three status values only. Green means filed or paid with evidence. Amber means due within seven days. Red means overdue, with the late fee and the fix date. Our compliance calendar for 2026-27 lists the full year.
How should the pack track the transfer pricing markup?
Track it monthly on the cost base that the benchmark study and the service agreement use. Compute cost, the markup earned, the amount billed and the true up still to invoice. Then compare the year to date markup with the agreed rate, the benchmark and the 15.5 percent safe harbour margin for IT services.
A year end surprise is expensive, because the parent may have closed its books by then. Take the cost base from the study, not from the MIS team's judgement. A study usually lists exclusions, such as interest, income tax and extraordinary items. Book the true up each month as unbilled revenue, and invoice it at least each quarter.
The safe harbour changed in 2026. The Union Budget of 1 Feb 2026 merged the IT categories into one, "Information Technology Services", as the PIB release records. It carries one margin of 15.5 percent, and the threshold rose from INR 300 crore to INR 2,000 crore. CBDT's release of 31 Mar 2026 repeats both figures.
The safe harbour sits in section 167 of the Income Tax Act, 2025. Rule 88 of the Income Tax Rules, 2026 lists the eligible transactions. Rule 89 sets the margin at an operating profit of at least 15.5 percent on operating expense. Operating revenue must not exceed INR 2,000 crore. Rule 89 applies for a block of three tax years starting with tax year 2026-27.
Rule 91 covers the procedure for IT services. The department verifies the option electronically, and a valid option runs for five consecutive tax years. The INR 2,000 crore test applies to the first of those years.
The company files Form 49 for that first year. Rule 91(3) on the department's site ties its due date to the return due date under section 263(1)(c). The Form 49 FAQs and guidance note say 30 June of the next financial year. We file by 30 June, which meets both. Our safe harbour guide covers the conditions.
A centre on cost plus 15 percent sits 0.5 points below the safe harbour margin. On our reading, it cannot opt in at 15 percent. It either reprices to 15.5 percent or defends 15 percent with a benchmark study in Form 48. The MIS should show both lines, so the parent can price the choice.
| Column in the markup tracker | Definition |
|---|---|
| Operating cost | Costs inside the cost base as the agreement and study define it |
| Amount invoiced | Provisional invoice to the parent |
| Revenue at the agreed markup | Operating cost × (1 + agreed markup) |
| True up | Revenue at the agreed markup − amount invoiced, booked as unbilled revenue |
| Markup billed on actual cost | (Amount invoiced − operating cost) ÷ operating cost |
| Year to date markup earned | (Year to date revenue − year to date cost) ÷ year to date cost |
| Benchmark and safe harbour test | Year to date markup against the study and against 15.5% |
Rule 84 of the Income Tax Rules, 2026 requires the local file where international transactions exceed INR 1 crore in the year. Form 48, the transfer pricing report that replaced Form 3CEB, is due one month before the return due date (rule 85). For a US parent, see our note on transfer pricing between a US parent and its Indian subsidiary.
How does the MIS feed the parent's group reporting pack?
The MIS runs on Indian books under AS or Ind AS. The group pack uses the parent's GAAP, currency and calendar. A bridge connects them in four steps: map the chart of accounts, post GAAP adjustments, match intercompany balances and translate the currency. Build the bridge once and run it each month.
| Area | Indian books | Group pack (IFRS or US GAAP) | What the monthly pack does |
|---|---|---|---|
| Year end | 31 March under section 2(41), Companies Act, 2013 | The parent's year end, often 31 December | Shows both year to date views |
| Framework | AS; Ind AS from INR 250 crore of net worth or by choice | IFRS or US GAAP | Keeps a GAAP bridge by line |
| Leases | AS 19 expenses operating lease rent | IFRS 16 or ASC 842 records a right of use asset and a lease liability | Adds a lease schedule |
| Employee benefits | Gratuity and leave under AS 15 or Ind AS 19 | IAS 19 or ASC 715 | Uses one actuary |
| Parent share awards to Indian staff | Recharge from the parent, if any | IFRS 2 or ASC 718 charge | Reports grants and recharges apart |
| Deferred tax | AS 22 timing differences | IAS 12 or ASC 740 temporary differences | Leaves it to group tax |
| Foreign currency | AS 11 restates monetary items at the closing rate | IAS 21 or ASC 830 | Restates balances each month |
Intercompany differences come from four places. Timing is the first: an invoice raised on 30 September may reach the parent's books in October. Exchange rates are the second, when each side books at a different rate.
Indian TDS is the third. When the subsidiary pays the parent a licence fee, it deducts tax under section 393(2), and the parent books the gross amount. Disputes are the fourth. Match to zero each month or list each reconciling item with its expected clearing date.
Currency translation follows the parent's standard. Under paragraph 39 of IAS 21, assets and liabilities translate at the closing rate. Income and expenses translate at the rates on the transaction dates. The resulting exchange differences go to other comprehensive income. Paragraph 40 allows an average rate for the period when it approximates the transaction rates, but not when rates swing sharply. US GAAP (ASC 830) uses the current rate method where the foreign entity's functional currency is its local currency.
Most Indian subsidiaries have INR as their functional currency, because salaries and rent are in INR. A captive centre should still record its assessment. Paragraph 11(a) of IAS 21 asks whether the operation works as an extension of the parent or with a significant degree of autonomy. Indian tax rules use the telegraphic transfer buying rate in rule 207 for some conversions, so keep tax rates apart from group rates.
Our guide to financial reporting for foreign subsidiaries covers the GAAP differences in more depth.
How fast should the monthly pack close?
We aim for a flash report by working day 5 and the full pack by working day 10. That timetable is our practice, not a legal rule. The parent's consolidation calendar sets the real deadline, so fix it in the reporting manual and plan the close backwards from it.
| Working day | Tasks | Owner |
|---|---|---|
| Before day 1 | Freeze payroll inputs, request accruals, agree the cut off with the parent | Finance head |
| Day 1 | Download bank statements, post payroll, raise the provisional invoice to the parent | Accountant |
| Day 2 | Post supplier bills and accruals, release prepaid expenses, run depreciation | Accountant |
| Day 3 | Restate foreign currency balances, compute the markup true up, send the intercompany confirmation | Accountant |
| Day 4 | Book gratuity, leave, bonus and tax provisions; review balance sheet schedules | Finance head |
| Day 5 | Send the flash report to the parent | Finance head |
| Day 6 | Map to the group chart of accounts, run the GAAP bridge, match intercompany | Accountant |
| Day 7 | Update the compliance block with challan and filing references | Compliance lead |
| Day 8 | Calculate KPIs, draft variance commentary, update the forecast | Finance head |
| Day 9 | Review with the managing director; clear the parent's FP&A queries | Managing director |
| Day 10 | Issue the final pack and the group pack; lock the period | Finance head |
Statutory dates are calendar dates, not working days. TDS for the month is due by the 7th under rule 218(2), whichever close day that falls on. So we pay TDS from the payroll and supplier data before the pack is final. GSTR-1 (11th) and GSTR-3B (20th) fall after the pack, so the block reports the previous month's filings.
How do you write variance commentary the parent can use?
Explain every variance above an agreed threshold in five parts. State what moved, by how much, why, whether it recurs and what happens next. Name an owner and a date for the action. In our practice the threshold is INR 1 lakh or 5 percent of the line, whichever is higher, unless the parent sets its own. No rule fixes it.
A "timing" comment is acceptable only with the month in which the difference reverses. The strong comments below use illustrative figures from the worked example.
| Weak comment | Strong comment |
|---|---|
| Travel over budget. | Travel INR 0.90 lakh over budget: two engineers spent ten days at the parent for the release. One off; approved by the parent's engineering head. |
| Timing difference. | Professional fees INR 0.90 lakh over: tax audit and Form 3CEB fees accrued in September against an October budget. Nil variance for the year. |
| Payroll higher due to statutory changes. | Employer PF up INR 0.34 lakh: the EPF wage ceiling rose to INR 25,000 from 17 Sep 2026. Recurs at INR 0.72 lakh a month; forecast updated. |
| Headcount below plan. | Two open roles, replacing a June leaver and a September leaver. Joining on 5 Oct and 19 Oct 2026. |
Put the commentary beside the numbers in full sentences, because the parent's FP&A team copies it into the group commentary.
What format and tools work for an MIS report?
A spreadsheet pack on a locked template works for a single entity with moderate volumes. Larger groups feed the ledger into a reporting tool and the parent's consolidation system. The tool matters less than three habits: a fixed layout, a trail from every figure back to the ledger and version control. The ledger itself must meet the Companies (Accounts) Rules, 2014.
| Need | Common options | India check |
|---|---|---|
| Ledger | Tally Prime, Zoho Books, SAP Business One, Oracle NetSuite, Microsoft Dynamics 365 Business Central | Audit trail that nobody can disable (rule 3(1)); daily backup in India (rule 3(5)) |
| Payroll | Indian payroll software or a payroll provider | PF, ESI, professional tax and salary TDS for Form 138 |
| Pack and KPIs | Excel or Google Sheets on a locked template; Power BI or Looker Studio | Every figure links to the trial balance |
| Consolidation | The parent's system, such as Oracle EPM, OneStream or Anaplan | Account mapping kept in the appendix |
The audit trail rule matters most when the parent runs the ERP. The proviso to rule 3(1) of the Companies (Accounts) Rules, 2014 requires software that logs every change in an audit trail. Nobody may disable it. It applies from financial years starting 1 Apr 2023. The books must stay accessible in India, with a daily backup on servers located in India (rule 3(5)).
Where a service provider hosts the books, rule 3(6) requires yearly details to the Registrar. These include the provider's name, IP address and location. Where the provider is outside India, they also include the person in India who controls the books. We set up ledgers to these rules under our accounting and bookkeeping service, and run the monthly pack under our eCFO service.
Which controls keep the numbers reliable?
Reliable numbers come from a few controls, run every month and evidenced. Bank and intercompany reconciliations, journal approval, a period lock and statutory ledger reconciliations do most of the work. Each control should leave a record that the statutory auditor can test.
| Control | What it catches | Evidence |
|---|---|---|
| Bank reconciliation | Missed receipts, duplicate payments | Signed reconciliation |
| Maker and checker on journals | Unsupported entries | Approver in the audit trail |
| Period lock after day 10 | Back dated changes after the pack goes out | Lock date log |
| Intercompany confirmation | Mismatches with the parent | Confirmation signed by both sides |
| GST reconciliation (books, GSTR-1, GSTR-3B, GSTR-2B) | Short paid tax, lost credit | Reconciliation file |
| TDS reconciliation (books, challans, Form 168) | Short deduction, missed credit | Reconciliation file |
| Payroll against HR headcount | Ghost employees, missed leavers | Signed headcount tie out |
| User access review | Users with rights they should not hold | Signed user list |
The statutory auditor reports on internal financial controls under section 143(3)(i) of the Companies Act, 2013, unless the company is exempt. Internal audit under section 138 binds a private company with turnover of INR 200 crore or more. It also binds one whose bank or public financial institution loans topped INR 100 crore during the preceding year. Rule 13 of the Companies (Accounts) Rules, 2014 sets both tests. Our note on the statutory audit of a foreign owned subsidiary lists what the auditor requests.
How does an MIS report differ from statutory accounts?
The MIS is an internal monthly pack in whatever format management chooses. Statutory accounts are the annual financial statements the Companies Act, 2013 requires. They follow section 129 and Schedule III under AS or Ind AS, and a Chartered Accountant audits them. The MIS guides decisions; the statutory accounts go to members, the Registrar and the tax authorities.
| Point | MIS pack | Statutory financial statements |
|---|---|---|
| Legal basis | None; internal | Sections 128 and 129 and Schedule III, Companies Act, 2013 |
| Frequency | Monthly, with a quarterly board pack | Annual |
| Deadline | The parent's calendar | AGM within six months of year end; AOC-4 within 30 days of the AGM |
| Readers | Parent, board, management | Members, Registrar of Companies, tax authorities, banks |
| Framework | Management basis or group GAAP | AS or Ind AS |
| Currency | INR plus the parent currency | INR |
| Assurance | Internal review | Audit under section 143 |
| Content | KPIs, headcount, forecast, commentary | Prescribed statements and notes |
The March MIS should equal the draft statutory accounts before audit adjustments. Post each audit adjustment back into the MIS, so April's year to date figures start from audited balances.
What changed in 2026
Several 2026 changes reach the monthly pack of a foreign owned subsidiary. The largest are the new income tax law and forms, the safe harbour for IT services, the FEMA export rules and the EPF wage ceiling.
| Area | Before | Now | From | Instrument |
|---|---|---|---|---|
| Income tax law and forms | Income Tax Act, 1961; Forms 24Q, 26Q, 27Q, 16A, 15CA, 15CB, 3CD, 3CEB | Income Tax Act, 2025; tax year; Forms 138, 140, 144, 131, 145, 146, 26, 48 | 1 Apr 2026 | Act 30 of 2025; Income Tax Rules, 2026 (G.S.R. 198(E), 20 Mar 2026) |
| Safe harbour for IT services | Separate categories; INR 300 crore threshold | One category at 15.5% of operating expense; INR 2,000 crore threshold; electronic verification; option for five tax years | Tax year 2026-27 (announced 1 Feb 2026) | Section 167; rules 88, 89 and 91; Form 49 |
| ECB reporting | Monthly Form ECB 2 within seven working days | Form ECB 2 within seven calendar days after a month with a drawdown or debt servicing | 16 Feb 2026 | FEMA 3(R)(5)/2026-RB |
| Export of services | SOFTEX under the 2015 regulations; realisation in nine months (fifteen from the 13 Nov 2025 amendment until the 5 Jun 2026 amendment) | EDF within 30 days of the invoice month end; realisation within nine months of the invoice, twelve if invoiced or settled in INR | 1 Oct 2026; periods cut from fifteen and eighteen months on 22 Sep 2026 | FEMA 23(R)/2026-RB; FEMA 23(R)/(1)/2026-RB |
| EPF wage ceiling | INR 15,000 a month | INR 25,000 a month; September 2026 split at 17 Sep | 17 Sep 2026 | S.O. 5109(E); EPFO FAQs |
| Wages for gratuity and leave | Old labour laws | Code wages under the four labour codes | Codes 21 Nov 2025; central rules 8 May 2026 | S.O. 5319(E) to 5322(E); G.S.R. 342(E) to 345(E) |
| DIR-3 KYC | Every year by 30 September | By 30 June after every third financial year; next by 30 Jun 2028 for directors whose KYC is current | 31 Mar 2026 | G.S.R. 943(E), 31 Dec 2025; PIB release, 1 Jan 2026 |
Two of these change the cost base itself. For staff whose PF the company caps at the ceiling, employer PF moves from INR 1,800 to INR 3,000 a month. The labour codes moved gratuity to Code wages. Both flow into the markup, so the service fee rises with them. Our note on the new labour codes covers the payroll side.
Worked example
This example is an illustration. DevCo and every figure below are invented to show the method, and none comes from a client.
The company
DevCo India Private Limited is an invented wholly owned subsidiary of a US company with a 31 December year end. It runs a 60 person software development centre. A service agreement pays it operating cost plus 15 percent. DevCo invoices each month at budgeted cost × 1.15 and trues up to actual cost each quarter. It has no borrowings.
Amounts are in INR lakh unless stated. The US dollar figures use an assumed rate of INR 88.00 per USD, not a market rate.
The one page summary for September 2026 (illustrative)
| Measure | Sep 2026 actual | Sep 2026 budget | Variance | Jul to Sep 2026 actual |
|---|---|---|---|---|
| Closing headcount (number) | 60 | 62 | 2 below | 60 |
| Total operating cost | 88.40 | 86.00 | 2.40 adverse | 260.00 |
| Service revenue at cost plus 15% | 101.66 | 98.90 | 2.76 above | 299.00 |
| Of which invoiced | 98.90 | 98.90 | 0.00 | 294.86 |
| Of which unbilled true up | 2.76 | 0.00 | 2.76 | 4.14 |
| Operating profit | 13.26 | 12.90 | 0.36 above | 39.00 |
| Markup earned on actual cost | 15.0% | 15.0% | 0.0 points | 15.0% |
| Markup billed on actual cost | 11.9% | 15.0% | 3.1 points short | 13.4% |
| Foreign exchange gain (outside the cost base) | 0.80 | 0.00 | 0.80 | 1.10 |
| Interest on deposits | 0.30 | 0.30 | 0.00 | 0.85 |
| Profit before tax | 14.36 | 13.20 | 1.16 above | 40.95 |
| Cost per average FTE (INR) | 1,46,116 | 1,38,710 | 7,406 adverse | Not shown |
| Closing cash and bank | 145.20 | 140.00 | 5.20 above | 145.20 |
| DSO (days) | 29 | 30 | 1 better | 29 |
| Compliance | Green; TDS for September paid by 7 Oct 2026; Forms 138, 140 and 144 and MSME Form 1 due 31 Oct 2026 |
Revenue at cost plus 15 percent is 88.40 × 1.15 = 101.66. The invoice was 86.00 × 1.15 = 98.90, so the true up is 2.76. Operating profit is 101.66 − 88.40 = 13.26.
Headcount fell from 61 to 60, so average FTE is 60.5. Cost per FTE is INR 88,40,000 ÷ 60.5 = INR 1,46,116. The budget assumes 62 heads for the whole month, so its figure is INR 86,00,000 ÷ 62 = INR 1,38,710. At the assumed rate, revenue is USD 115,523 and operating profit is USD 15,068.
The variance commentary
| Ref | Line | Actual | Budget | Variance | Cause | Action and owner |
|---|---|---|---|---|---|---|
| V1 | Salaries | 64.20 | 65.00 | 0.80 favourable | Two replacement roles open | Joiners on 5 Oct and 19 Oct 2026; HR lead |
| V2 | Employer PF, gratuity and leave | 5.10 | 4.40 | 0.70 adverse | EPF ceiling of INR 25,000 from 17 Sep 2026 (0.34); half year actuarial update at Code wages (0.36) | Rebase the October to December forecast for PF at 0.72 a month; finance head |
| V3 | Travel | 1.90 | 1.00 | 0.90 adverse | Two engineers at the parent for a release | None; one off, approved by the parent |
| V4 | Professional fees | 2.10 | 1.20 | 0.90 adverse | FY 2025-26 tax audit and Form 3CEB fees accrued early | Reverses in October |
| V5 | Software licences | 3.40 | 3.20 | 0.20 adverse | Three extra licences | Add to the budget; engineering head |
| V6 | Other administration | 1.20 | 0.70 | 0.50 adverse | Recruitment agency fees for the replacements | None; one off |
| Staff welfare, rent, depreciation | 10.50 | 10.50 | 0.00 | On budget | ||
| Total operating cost | 88.40 | 86.00 | 2.40 adverse |
The PF line needs one assumption. The EPFO FAQs split the September 2026 wage month at 17 Sep. Days 1 to 16 use the INR 15,000 ceiling, and days 17 to 30 use INR 25,000. We prorated the extra INR 1,200 a month by days, so 14 of 30 days gives INR 560 per capped employee. For 60 capped employees, that is INR 33,600, or 0.34 lakh. From October, the full extra cost is 60 × INR 1,200 = INR 72,000 a month, or 0.72 lakh.
The markup check
| Month | Actual operating cost | Invoiced (budget cost × 1.15) | Revenue at actual cost × 1.15 | True up | Markup billed on actual cost |
|---|---|---|---|---|---|
| Jul 2026 | 85.20 | 97.75 | 97.98 | 0.23 | 14.73% |
| Aug 2026 | 86.40 | 98.21 | 99.36 | 1.15 | 13.67% |
| Sep 2026 | 88.40 | 98.90 | 101.66 | 2.76 | 11.88% |
| Jul to Sep total | 260.00 | 294.86 | 299.00 | 4.14 | 13.41% |
The billed markup for the quarter is (294.86 − 260.00) ÷ 260.00 = 13.41 percent. DevCo books the INR 4.14 lakh true up as unbilled revenue and invoices it by 15 Oct 2026. After the true up, the quarter's markup is (299.00 − 260.00) ÷ 260.00 = 15.00 percent.
At the 15.5 percent safe harbour margin, July to September revenue would be 260.00 × 1.155 = 300.30, which is 1.30 more. On a similar cost base for four quarters, the gap is about INR 5.2 lakh a year. The pack puts that figure beside the cost of the annual benchmark study, and the parent decides whether to reprice.
The true up invoice is an export of services. To invoice it at zero rate without paying IGST, DevCo needs its LUT for FY 2026-27 on file. An invoice raised in October 2026 also needs an EDF within 30 days from the end of October, so by 30 Nov 2026. Our EDF guide covers the filing.
The compliance lines in the September pack
The flash report on working day 5 showed TDS for September as amber, due 7 Oct 2026. The final pack shows it green with the challan number. Forms 138, 140 and 144 for July to September are due 31 Oct 2026. MSME Form 1 for April to September has the same date, if a micro or small supplier waited beyond 45 days. The AGM met on 22 Sep 2026. So AOC-4 is due by 22 Oct 2026 and MGT-7 by 21 Nov 2026.
Common mistakes
- Sending the parent a ledger dump. Fix: open with the one page summary and move detail to the appendices.
- Changing KPI definitions mid year. Fix: keep a KPI dictionary and restate prior months when a definition changes.
- Invoicing on budget cost and never truing up. Fix: accrue the true up monthly and invoice it each quarter.
- Assuming cost plus 15 percent is inside the safe harbour. The 2026 margin for IT services is 15.5 percent. Fix: show the gap in the pack and let the parent choose.
- Tracking compliance with ticks. Fix: record the challan, ARN, SRN or acknowledgement number for each item.
- Using old form numbers. Forms 24Q, 26Q and 27Q became Forms 138, 140 and 144 from 1 Apr 2026. Fix: update the compliance block and the payroll software.
- Ignoring the FEMA realisation clock on intercompany invoices. Fix: flag export invoices older than 180 days, well before the nine month limit.
- Leaving intercompany differences unexplained. Fix: match monthly and list each reconciling item, including TDS on payments to the parent.
- Running the MIS on unaudited opening balances. Fix: post audit adjustments back as soon as the auditor agrees them.
- Missing payroll cost changes in the forecast. Fix: rebase the forecast in the month the EPF ceiling or a wage change takes effect.
Checklist
- Agree the pack's sections, definitions, exchange rate source, commentary threshold and deadline with the parent in a reporting manual.
- Set up the ledger with an audit trail that cannot be disabled and a daily backup on servers in India.
- Map the Indian chart of accounts to the group chart of accounts, and document the GAAP adjustments.
- Build a locked template with the one page summary, the twelve sections and the KPI dictionary.
- Load the service agreement's cost base and markup into a markup tracker.
- List every statutory item with its due date, owner and evidence field in the compliance block.
- Close the books to a reviewed trial balance by working day 4.
- Pay TDS by the 7th and record the challan in the compliance block.
- Send the flash report by working day 5.
- Match intercompany balances and run the GAAP bridge and currency translation.
- Write variance commentary for every line above the threshold, with a cause, an owner and a date.
- Issue the final pack by working day 10 and lock the period.
- Compare the year to date markup with the agreement, the benchmark and the 15.5 percent safe harbour each quarter.
To have us build or run your monthly pack, send your latest trial balance and intercompany agreement through our contact page.
Frequently Asked Questions
What is the full form of MIS in accounting?
MIS stands for management information system. In accounting, an MIS report is the periodic internal report that summarises the books for managers. It shows results against budget, cash, receivables, payables, headcount and KPIs, with commentary. It is separate from the statutory financial statements under section 129 of the Companies Act, 2013, which report the year to members and the Registrar.
Is an MIS report mandatory for a Private Limited company in India?
No statute requires a Private Limited company to prepare an MIS report or prescribes its format. Section 128 of the Companies Act, 2013 requires proper books of account, and the MIS draws on them. In practice, a foreign parent, lender or investor requires one by contract. Boards also need current figures for the four meetings a year under section 173(1).
How is an MIS report different from management accounts?
Management accounts are the financial core of the MIS: the income statement, balance sheet and cash flow for internal use. An MIS pack adds operating data such as headcount, receivables ageing, KPIs and compliance status, plus commentary and a forecast. For a foreign owned subsidiary, it also carries the transfer pricing markup check.
Who prepares the MIS report in an Indian subsidiary?
The local finance head or accountant prepares it from the books and payroll, and the managing director reviews it. Many foreign owned subsidiaries outsource the monthly close and the pack to a virtual CFO provider. Either way, name one owner for each section and fix the calendar in a reporting manual.
What is a flash report?
A flash report is a short early view of the month, sent before the full close. It usually shows revenue, operating cost, cash and headcount against budget. We send it by working day 5, and the full MIS pack follows by working day 10. The flash lets the parent start its own consolidation while the Indian team completes the close.
Should the MIS be in INR or in the parent's currency?
Show both. The Indian books are in INR, so the MIS starts there, and the parent consolidates in its own currency. Use the rate table the parent's treasury publishes and state it on the cover. Under IAS 21 (paragraphs 39 and 40), assets and liabilities use the closing rate. Income and expenses use transaction or average rates.
Should the MIS follow Indian GAAP or the parent's GAAP?
Prepare the MIS from the Indian books, which follow AS or Ind AS, and add a GAAP bridge to IFRS or US GAAP. The bridge covers leases, employee benefits, share based payments, deferred tax and depreciation. A subsidiary moves to Ind AS once its own net worth reaches INR 250 crore, or if it opts in. The parent's framework does not decide it.
How does the MIS work when the parent has a December year end?
The Indian subsidiary still closes its statutory year on 31 March under section 2(41) of the Companies Act, 2013. A different year needs Central Government approval, open only to a subsidiary that needs it for consolidation abroad. The MIS therefore shows two year to date views: April to date for India and January to date for the group. The statutory audit remains on the March accounts.
How often should the transfer pricing markup be trued up?
Track it monthly and invoice the true up at least each quarter. Book the monthly difference as unbilled revenue, so the income statement always shows the agreed markup. A single year end adjustment can land after the parent closes its books. It also risks a mismatch with the Form 48 transfer pricing report, due one month before the return due date under rule 85.
Can a development centre on cost plus 15 percent use the 2026 safe harbour?
On our reading, not at 15 percent. From tax year 2026-27, rule 89 of the Income Tax Rules, 2026 sets one IT services margin of 15.5 percent on operating expense. Operating revenue must not exceed INR 2,000 crore. A centre at 15 percent can reprice to 15.5 percent and opt in through Form 49 under section 167. Or it can defend 15 percent with a benchmark study.
Which forms replaced Forms 24Q, 26Q and 27Q in the compliance block?
From 1 Apr 2026, the quarterly TDS statements are Form 138 for salary and Form 140 for other payments to residents. Form 144 covers payments to non residents. Rule 219 of the Income Tax Rules, 2026 sets the due dates: 31 July, 31 October, 31 January and 31 May. Form 131 replaced Form 16A, and Forms 145 and 146 replaced Forms 15CA and 15CB.
Does the MIS need to track export receivables for FEMA?
Yes, if the subsidiary exports services to its parent or other customers abroad. From 1 Oct 2026, regulation 5(1)(a) of FEMA 23(R)/2026-RB requires realisation within nine months of the invoice date. The limit is twelve months if the export is invoiced or settled in INR. FEMA 23(R)/(1)/2026-RB of 22 Sep 2026 set these periods, down from fifteen and eighteen months. Regulation 3(2) requires an EDF within 30 days from the end of the invoice month.
What should the board see from the MIS at board meetings?
The board should see a quarterly board pack built from the monthly MIS. It covers results against budget, cash and funding, KPIs, the compliance status, key risks and the decisions the board must take. Section 173(1) of the Companies Act, 2013 requires at least four board meetings a year, with no more than 120 days between two meetings.
How long should we keep MIS packs?
No rule sets a retention period for MIS packs as such. Section 128(5) of the Companies Act, 2013 requires the books of account and vouchers for at least eight financial years. We keep each month's final pack, trial balance and reconciliations with the books for the same period, so they support audits and tax assessments.
What does a bank lender expect in the MIS?
Lenders usually ask for monthly or quarterly results, receivables and stock statements, and covenant calculations under the sanction letter. CARO 2020 clause 3(ii)(b) covers quarterly returns to banks where working capital limits above INR 5 crore rest on current assets. The auditor checks whether those returns agree with the books, so prepare them from the same ledger as the MIS.
Sources
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