New Reporting for Foreign Entities' LO/BO/PO in India
Current · Source: Reserve Bank of India · RBI/2012-13/222 · issued 25 Sep 2012 · ~2 min read
Quick answerRBI now requires all new and existing LO/BO/PO of foreign entities to submit an Annex report to the state DGP within five working days of becoming functional, and annually thereafter, with a copy to the AD bank.
The rule, in the simplest words
Any foreign company that opens a Liaison Office (LO - a small office that can only do limited work), Branch Office (BO - a bigger office that can do business), or Project Office (PO - an office for a specific project) in India must send a special report (called Annex report) to the state police chief (Director General of Police or DGP) within 5 working days of the office starting work.
After the first report, the foreign company must also send the same Annex report every year to the state police chief, along with their yearly activity certificate or report.
The foreign company must give a copy of that Annex report to their bank (called Authorised Dealer or AD bank) every time they send it to the police chief.
Offices that already exist (old LO/BO/PO) must now also start sending this Annex report every year to the state police chief and their bank, together with their yearly activity report.
How it plays out — a real example
Priya, a compliance officer at a large bank in Mumbai, gets a call from a new foreign client setting up a Branch Office in Pune. She reminds the client's manager: 'Within 5 working days of your office opening, you must send the Annex report to the Maharashtra DGP and give us a copy. And every year after that, do the same along with your annual activity report. I'll keep a copy in our files to stay compliant.'
What changed
RBI has added a new reporting requirement for all foreign entities setting up Liaison Offices (LO), Branch Offices (BO), or Project Offices (PO) in India. In addition to existing annual activity reports, these entities must now submit a report (as per Annex) to the Director General of Police (DGP) of the concerned state within five working days of becoming functional. Existing LO/BO/PO must also file this Annex report annually along with their activity certificate/report to the DGP and AD bank.
What it means for you
Banks acting as Authorised Dealers must ensure their foreign entity customers comply with this new police reporting requirement. This adds a layer of security and regulatory oversight, requiring banks to track and verify that the Annex report is filed with the DGP and a copy is submitted to them. Non-compliance could lead to regulatory action against the foreign entity and the AD bank.
What you must do
Inform all existing and new LO/BO/PO customers about the new DGP reporting requirement immediately.
Update your internal compliance checklists to include verification of the Annex report submission to the DGP within five working days of the entity becoming functional.
Ensure that copies of the DGP-filed Annex report are collected from customers and maintained in your records.
Train your relationship managers and compliance teams on the new reporting timeline and documentation requirements.
Who it affects
Authorised Dealer Category – I banks, Foreign entities with LO/BO/PO in India, State Director General of Police offices
❓ Common questions
What is the new reporting requirement for LO/BO/PO?
New entities must submit a report (as per Annex) to the state DGP within five working days of becoming functional. Existing entities must file this report annually along with their activity certificate/report.
Do existing LO/BO/PO need to comply immediately?
Yes, the circular is effective immediately. Existing LO/BO/PO must start filing the Annex report annually with the DGP and provide a copy to the AD bank.
What is the bank's role in this new requirement?
AD banks must bring this circular to the notice of their customers and ensure that copies of the DGP-filed reports are submitted to them for compliance monitoring.
📜 Read the original circular — full text as issued by RBI
RBI/2012-13/222
A. P. (DIR Series) Circular No. 35
September 25, 2012
To
All Category - I Authorised Dealer Banks
Madam / Sir,
Establishment of Liaison Offices (LO) /Branch Offices (BO) / Project Offices
(PO) in India by Foreign Entities – Reporting requirement
Attention of Authorised Dealer Category – I banks is invited to A.P. (DIR Series) Circular No. 6 dated August 9, 2010 read with paragraph 5 (i) of A.P. (DIR Series) Circular No.24 dated December 30, 2009 regarding submission of Annual Activity Report. Their attention is also drawn to reporting requirements in respect of Project Offices prescribed in A.P. (DIR Series) Circular No. 44 dated May 17, 2005 in the matter.
2. It has now been decided that in addition to the reporting prescribed in terms of aforesaid circulars, all the new entities setting up LO/BO/PO shall also:
submit a report containing information as per Annex within five working days of the LO/BO/PO becoming functional to the Director General of Police (DGP) of the state concerned in which LO/BO/PO has established its office; if there are more than one office of such a foreign entity, in such cases to each of the DGP concerned of the state where it has established office in India;
a copy of the report as per Annex shall also be filed with the DGP concerned on annual basis along with a copy of the Annual Activity Certificate/Annual report required to be submitted by LO/BO/PO concerned, as the case may be.
A copy of report thus filed as above shall also be filed with AD by LO/BO/PO concerned.
3. The existing LO/BO/PO shall henceforth report the information as per Annex along with the copy of Annual Activity Certificate/Annual report to DGP of state concerned and also file a copy of the same with AD bank.
4. The instructions come into force with immediate effect. AD Category – I banks may bring the contents of this circular to the notice of their constituents and customers concerned.
5. 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 permission/approval, required under any other law.
Yours faithfully,
(Rudra Narayan Kar)
Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2012-13/222 · issued 25 Sep 2012. The plain-English explanation above is BankPulse’s own independent summary.
Example: if you are a Compliance officer at a bank this circular applies to (Authorised Dealer Category – I banks, Foreign entities with LO/BO/PO in India, State Director General of Police offices), your first concrete step on “New Reporting for Foreign Entities' LO/BO/PO in India” is: “Inform all existing and new LO/BO/PO customers about the new DGP reporting requirement immediately.” (RBI issued this 25 Sep 2012).
Circular: RBI/2012-13/222 -- New Reporting for Foreign Entities' LO/BO/PO in India
Issued: 25 Sep 2012
Action required: Inform all existing and new LO/BO/PO customers about the new DGP reporting requirement immediately.
Action required: Update your internal compliance checklists to include verification of the Annex report submission to the DGP within five working days of the entity becoming functional.
Action required: Ensure that copies of the DGP-filed Annex report are collected from customers and maintained in your records.
Action required: Train your relationship managers and compliance teams on the new reporting timeline and documentation requirements.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
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.
💬 Banker Discussion
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BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=7589&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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