Reserve Bank of India waives late fees and allows 180 days to report past issuances of partly paid units on FIRMS portal

The Reserve Bank of India issued directions to Authorised Dealer Category I banks on FIRMS portal reporting for investment vehicles issuing partly paid units to persons resident outside India. The circular provides a transitional reporting window for issuances made before the circular’s date, while retaining the standard reporting timeline for new issuances. Under Regulation 4(10) of the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019, investment vehicles must file Form InVI within 30 days of issuing units to non-residents. For partly paid units issued prior to the circular, reporting in Form InVI may be completed within 180 days from the circular’s date without late submission fees; issuances on or after the circular’s date must continue to be reported within 30 days. The directions take immediate effect and AD Category I banks are expected to notify relevant customers.