CS Vinita Nair

After SEBI’s circular dated April 10, 2018 for monitoring foreign investment limits in listed Indian companies, RBI on June 7, 2018 issued notification in relation to reporting of foreign investment in Indian companies/ LLPs/ start up. RBI is to provide interface from June 28, 2018 to July 12, 2018.

Online application of RBI: FIRMS (Foreign Investment Reporting and Management System): https://firms.rbi.org.in. FIRMS would be made online in two phases.

Phase 1: Reporting in Entity Master. The first module will be available to the public for data entry between June 28 (at 1:00 pm) and July 12, 2018. Entities shall provide data with respect to all foreign investments received, irrespective of the fact that the regulatory reporting to the Reserve Bank for the same has been made or not and whether the same has been acknowledged or not.

The User Manual for filing entity manual can be accessed here.

Phase 2: The second module containing 9 reports (ARF, FC-GPR, DI, FC-TRS, LLP-I, LLP-II, ESOP, DRR and CN) i.e. Single Master Form would be made available with effect from August 01, 2018. The finalized structure of SMF and operational instructions thereof would be made available in the Master Direction on Reporting under FEMA, 1999.

Those not complying with this pre-requisite will not be able to receive foreign investment (including indirect foreign investment) and will be non-compliant with Foreign Exchange Management Act, 1999 and regulations made thereunder.

Matters to be ensured

Entity shall create user ID on FIRMS. The user has to attach the authority letter from the entity authorizing the person to register as the Entity User for submission of information in the Entity Master. The format of the authorization letter can be viewed here.

Refer the user manual for step wise information to be filed.





[The above post is contributed by CS Vinita Nair at Vinod Kothari & Co. She can be contacted at [email protected] ]

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June 2021