Why a Compliance Calendar Is Your Best FEMA Protection
The most common reason Indian companies end up with FEMA violations is not deliberate non-compliance — it is calendar blindness. In the daily complexity of running a business, regulatory deadlines that recur annually or event-based obligations that arise unexpectedly from cross-border transactions get lost. The cost of missing a single deadline can range from ₹7,500 (Late Submission Fee) to crores (compounding), depending on the nature of the default and how late it is discovered.
This calendar covers every material compliance deadline for Indian companies with FDI, ODI, ECB, ESOP, or other cross-border elements to their business — compiled from FEMA regulations, RBI Master Directions, MCA rules, and CBDT requirements.
Monthly Recurring Obligations
| By | Form / Filing | Authority | Applicable To |
| 7th of each month | ECB-2 Monthly Return | RBI via AD Bank | All entities with outstanding ECB |
| 11th of each month | GSTR-1 | GST Council | All GST-registered entities (monthly filers) |
| 20th of each month | GSTR-3B | GST Council | All GST-registered entities (monthly filers) |
Annual Compliance Calendar — Month by Month
January
- 7th — ECB-2 return for December (monthly recurring)
- 31st — ODI Annual Performance Report (APR): Final extended deadline — all APRs for the preceding calendar year must be filed by 31 January. This is the single most critical ODI compliance deadline.
March
- 31st — CbCR Notification (Form 3CEAC): Required for Indian entities that are constituent entities of large MNC groups (consolidated global turnover > ₹5,500 crore) — notification to the AO of which entity is filing the CbCR
- 31st — DIR-3 KYC (extended deadline in some years — check MCA portal for FY 2025-26 deadline)
April
- 15th — Advance Tax Q4 payment for individuals
- 1st onwards — New FEMA Guarantees Regulations 2026 fully operative — review all outstanding cross-border guarantees
June
- 15th — Advance Tax Q1 payment for companies
- 30th — DPT-3 (Return of Deposits) with ROC — for companies that have accepted loans from directors or shareholders classified as deposits
July
- 15th — Annual Return on Foreign Liabilities and Assets (FLA Return) — MANDATORY for every Indian company that has received FDI or made ODI at any point in its history. Filed online with RBI. Missing FLA return is a FEMA violation.
- 31st — Personal Income Tax Return filing, including Schedule FA (Foreign Assets) for individuals holding foreign assets or receiving foreign income
September
- 15th — Advance Tax Q2 payment for companies
- 30th — DIR-3 KYC: Annual KYC for all directors of Indian companies — filed electronically with DSC/OTP
October
- 31st — Form 48 (Transfer Pricing Report — replacing Form 3CEB from AY 2026-27): Filed by a Chartered Accountant reporting on international transactions and their arm’s length pricing. Companies with international AE transactions must file by this date.
- 31st — Income Tax Return for companies with international transactions (AE transactions or DTAA claims). Note: Companies without international transactions have different deadlines.
December
- 31st — ODI Annual Performance Report (APR): Repeat — this is the primary APR deadline for the preceding year’s entity performance. File by 31 December to avoid being blocked from further ODI transactions.
- 31st — GSTR-9 Annual Return and GSTR-9C (Reconciliation Statement) for GST-registered entities
Event-Based Obligations — The Most Commonly Missed
| Event | Deadline | Consequence of Missing |
| FDI received — share allotment | 60 days from remittance | Automatic FEMA violation |
| Share allotment to foreign investor | 30 days — file FC-GPR | FEMA violation — LSF or compounding |
| Secondary share transfer (resident-non-resident) | 60 days — file FC-TRS | FEMA violation |
| First ODI remittance | Before remittance — Form OI Part I + UIN | Cannot remit without UIN |
| New ODI financial commitment | Before commitment — update Form OI | Unauthorised financial commitment |
| ECB drawdown | After LRN — Form ECB 1 must be registered first | Unauthorised ECB |
| New ESOP grant to non-resident | Within 30 days of grant | FEMA ODI reporting default |
| 📞 Talk to SilverSix Consultant
SilverSix Consultant manages the entire FEMA compliance calendar for our retainer clients — ensuring no deadline is ever missed. Contact us to discuss a compliance retainer: [contact@silversix.pro | [+91 8160278403 |