Home › Circulars › RBI/2011-12/112

Regularization of Pre-FEMA Liaison/Branch Offices

Current · Source: Reserve Bank of India · RBI/2011-12/112 · issued 15 Jul 2011 · ~2 min read
Quick answerForeign entities with Liaison or Branch Offices in India set up before FEMA (June 1, 2000) without RBI approval must apply for regularization within 90 days of this circular. Applications go through their AD Category-I bank in Form FNC. Those with Government of India approval can also get a UIN.
The rule, in the simplest words
How it plays out — a real example

Rajesh, a compliance officer at a Mumbai AD bank, notices a foreign NGO client running a liaison office since 1998 without RBI approval. He immediately informs the NGO's CFO about the 90-day window, helps them fill Form FNC, and forwards it to RBI's Foreign Investment Division, ensuring the bank's records now show a valid application.

What changed

RBI noticed some foreign NGOs, NPOs, news agencies, and other entities were running LO/BOs in India without RBI approval after FEMA came into force. This circular gives them a one-time 90-day window to regularize their status. It also allows entities with prior Government of India approval to obtain a Unique Identification Number (UIN) from RBI.

What it means for you

Banks must actively identify customers operating LO/BOs without valid RBI approval and guide them to apply. This is a compliance checkpoint—banks need to verify approvals and keep copies on record. Failure to regularize could lead to regulatory action against the entity, and banks may face scrutiny for not ensuring compliance.

What you must do

Who it affects

AD Category-I banks, Foreign NGOs and NPOs with LO/BOs in India, Foreign news agencies and other foreign entities with pre-FEMA offices, Entities with Government of India approval for LO/BO

❓ Common questions

What is the deadline for regularization?

The circular gives 90 days from July 15, 2011, so the deadline was around October 13, 2011. However, this circular is historical; current rules may differ.

How do we apply for regularization?

Submit Form FNC through your AD Category-I bank where the LO/BO account is maintained. The bank forwards it to RBI's Foreign Investment Division, Central Office, Mumbai.

What if we already have Government of India approval?

You can approach RBI with a copy of that approval to get a Unique Identification Number (UIN).

📜 Read the original circular — full text as issued by RBI
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(DIR Series) Circular No. 02 July 15, 2011 To All Authorised Dealer Category - I banks Madam / Sir, Regularization of Liaison / Branch Offices of foreign entities established during the pre-FEMA period Attention of Authorised Dealer Category – I (AD Category-I) banks is invited to Notification No. FEMA 22/2000-RB dated May 3, 2000 viz. Foreign Exchange Management (Establishment in India of Branch or Office or other Place of Business) Regulations, 2000, as amended from time to time, read with A.P. (DIR Series) Circular Nos. 23 and 24 dated December 30, 2009 , in terms of which a person resident outside India requires the prior approval of the Reserve Bank of India for establishing a Liaison Office (LO) /Branch Office (BO) in India. Further, attention of the AD Category - I banks is invited to A.P. (DIR Series) Circular No. 23 dated December 30, 2009 in terms of which applications from foreign Non-Government Organisations (NGOs) / Non-Profit Organisations (NPOs) / Government bodies / Departments for establishing BO / LOs in India are considered by the Reserve Bank in consultation with the Government of India, Ministry of Finance. 2. It has come to the notice of the Reserve Bank that certain BOs / LOs established by the foreign NGOs, NPOs, news agencies and other foreign entities are continuing to function in India, without the approval of the Reserve Bank, after the Foreign Exchange Management Act (FEMA), 1999 came into force from June 1, 2000. Under the provisions of FEMA, 1999, ibid, the request of such entities to open an office in India is considered by the Reserve Bank in consultation with the Government of India, wherever required. 3. Accordingly, the foreign entities who have established LO or BO in India and continuing to function without obtaining permission from the Reserve Bank of India should approach the Reserve Bank within a period of 90 days from the date of issue of this circular for regularization of establishment of such offices in India, in terms of the extant FEMA provisions. 4. The foreign entities who may have established LO or BO with the permission from the Government of India may also approach the Reserve Bank along with a copy of the said approval for allotment of a Unique Identification Number (UIN) by the Reserve Bank of India. 5. All such applications/ requests should be submitted to the Chief General Manager-in-Charge, Reserve Bank of India, Foreign Exchange Department, Foreign Investment Division, Central Office, Fort, Mumbai – 400 001 in form FNC and should be routed through the AD Category – I bank where the account of such LO /BO is maintained. 6. AD Category - I banks may bring the contents of this circular to the notice of their constituents/ customers concerned and forward such application/ request to the Reserve Bank, after complying with the instructions contained in A.P. (DIR Series) Circular Nos. 23 and 24 dated December 30, 2009 . Further, they may also ensure that their constituents operating LO/ BO in India have valid approval from the Reserve Bank for the same and that a copy of such approval is kept on record. 7. The directions contained in this circular have been issued under sections 10(4) and 11(1) of the Foreign Exchange Management Act, 1999 (42 of 1999) and are without prejudice to permissions / approvals, if any, required under any other law. Yours faithfully, (Meena Hemchandra) Chief General Manager-in-Charge Related Press Release July 15, 2011 Regularization of Liaison / Branch Offices of foreign entities established during the pre-FEMA period 2026 All Months January February March April May June July August September October November December 2025 All Months January February March April May June July August September October November December 2024 All Months January February March April May June July August September October November December 2023 All Months January February March April May June July August September October November December 2022 All Months January February March April May June July August September October November December 2021 All Months January February March April May June July August September October November December 2020 All Months January February March April May June July August September October November December 2019 All Months January February March April May June July August September October November December 2018 All Months January February March April May June July August September October November December 2017 All Months January February March April May June July August September October November December Archives 2016 All Months January February March April May June July August September October November December 2015 All Months January February March April May June July August September October November December 2014 All Months January February March April May June July August September October November December 2013 All Months January February March April May June July August September October November December 2012 All Months January February March April May June July August September October November December 2011 All Months January February March April May June July August September October November December 2010 All Months January February March April May June July August September October November December 2009 All Months January February March April May June July August September October November December 2008 All Months January February March April May June July August September October November December 2007 All Months January February March April May June July August September October November December 2006 All Months January February March April May June July August September October November December 2005 All Months January February March April May June July August September October November December 2004 All Months January February March April May June July August September October November December 2003 All Months January February March April May June July August September October November December 2002 All Months January February March April May June July August September October November December 2001 All Months January February March April May June July August September October November December 2000 All Months January February March April May June July August September October November December 1999 All Months January February March April May June July August September October November December 1998 All Months January February March April May June July August September October November December 1997 All Months January February March April May June July August September October November December 1996 All Months January February March April May June July August September October November December 1995 All Months January February March April May June July August September October November December 1994 All Months January February March April May June July August September October November December 1993 All Months January February March April May June July August September October November December 1992 All Months January February March April May June July August September October November December 1991 All Months January February March April May June July August September October November December Top Back to previous page More Links Bank Holidays Banking Glossary Citizen's Charter Complaints Contact Us COVID-19 Measures E-LMS Events FAQs Financial Education Forms IFSC/MICR Codes Important Websites Opportunities @ RBI RBI Clarifications RBI Kehta Hai RBI’s Vision and Values (1257 kb)--> Right to Information Act Tenders Follow RBI RSS Twitter YouTube Instagram Facebook LinkedIn © Reserve Bank of India. 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Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/112 · issued 15 Jul 2011. The plain-English explanation above is BankPulse’s own independent summary.
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Who does what — compliance checklist
💻 IT / Systems
  • Follow the instructions in A.P. (DIR Series) Circular Nos. 23 and 24 dated December 30, 2009 while processing applications.
📜 Compliance
  • Notify all constituents with LO/BOs about the 90-day regularization window and the need for RBI approval.
  • Collect Form FNC from eligible entities and forward to RBI's Foreign Investment Division, Mumbai, after due diligence.
  • Verify that each LO/BO has valid RBI approval or Government of India approval (for UIN) and keep copies on record.
  • Monitor deadlines and ensure timely submission to RBI to avoid non-compliance.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template

Example: if you are a Compliance officer at a bank this circular applies to (AD Category-I banks, Foreign NGOs and NPOs with LO/BOs in India, Foreign news agencies and other foreign entities with pre-FEMA offices, Entities with Government of India approval for LO/BO), your first concrete step on “Regularization of Pre-FEMA Liaison/Branch Offices” is: “Notify all constituents with LO/BOs about the 90-day regularization window and the need for RBI approval.” (RBI issued this 15 Jul 2011).

  1. Circular: RBI/2011-12/112 -- Regularization of Pre-FEMA Liaison/Branch Offices
  2. Issued: 15 Jul 2011
  3. Action required: Notify all constituents with LO/BOs about the 90-day regularization window and the need for RBI approval.
  4. Action required: Collect Form FNC from eligible entities and forward to RBI's Foreign Investment Division, Mumbai, after due diligence.
  5. Action required: Verify that each LO/BO has valid RBI approval or Government of India approval (for UIN) and keep copies on record.
  6. Action required: Follow the instructions in A.P. (DIR Series) Circular Nos. 23 and 24 dated December 30, 2009 while processing applications.
  7. Action required: Monitor deadlines and ensure timely submission to RBI to avoid non-compliance.
  8. Owner: ____________ Target date: ____________
  9. Board/committee approval needed? Y / N
  10. Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=6612&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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