What changed
RBI has provided a one-time relaxation for investment vehicles to report issuances of partly paid units made before May 23, 2025, within 180 days from this circular's date, without any late submission fees. For issuances on or after this date, the existing 30-day reporting requirement under Form InVI remains unchanged.
What it means for you
Banks and investment vehicles now have a clear window to regularize past partly paid unit issuances without penalty, reducing compliance risk. This aligns with the 2024 amendment to FEMA rules allowing such issuances to non-residents. Lenders should update their internal systems to track both the 180-day window for past deals and the ongoing 30-day timeline for new issuances.
What you must do
- Advise investment vehicle clients to file Form InVI for past partly paid unit issuances within 180 days from May 23, 2025, to avoid late fees.
- Ensure new partly paid unit issuances on or after May 23, 2025, are reported within 30 days as per existing regulations.
- Update internal compliance checklists and training materials to reflect this circular's reporting timelines.
- Communicate the circular's contents to relevant customers and constituents promptly.
Who it affects
Category-I Authorised Dealer banks, Investment vehicles issuing partly paid units to non-residents, Non-resident investors in Indian investment vehicles
What is the deadline for reporting past partly paid unit issuances?
Investment vehicles must file Form InVI for partly paid units issued before May 23, 2025, within 180 days from that date, i.e., by November 19, 2025, with no late fee.
Does this circular change the reporting timeline for new partly paid unit issuances?
No. Issuances on or after May 23, 2025, must still be reported within 30 days as per the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019.