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RBI eases reporting for partly paid units of investment vehicles

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Current · Source: Reserve Bank of India · RBI/2025-26/40 · issued 23 May 2025 · ~2 min read
Quick answerRBI allows investment vehicles to report past partly paid unit issuances to residents outside India within 180 days via FIRMS portal, with no late fee. Future issuances must follow the standard 30-day reporting timeline.
The rule, in the simplest words
How it plays out — a real example

A forex & trade-finance officer in Indore notices that an investment vehicle client issued partly paid units to a non-resident investor in March 2025 but forgot to report it. Thanks to the new RBI rule, the officer advises the client to file Form InVI on the FIRMS portal within 180 days from May 23, 2025, so they can regularize the past issuance without paying any late fee, saving the client from a compliance headache.

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

Who it affects

Category-I Authorised Dealer banks, Investment vehicles issuing partly paid units to non-residents, Non-resident investors in Indian investment vehicles

❓ Common questions

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.

📜 Read the original circular — full text as issued by RBI
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(DIR Series) Circular No. 06 May 23, 2025 To All Category – I Authorised Dealer Banks Madam / Sir Reporting on FIRMS portal – Issuance of Partly Paid Units by Investment Vehicles Attention of Authorised Dealer (AD) Category - I banks is invited to the Foreign Exchange Management (Non-debt Instruments) Rules, 2019 (hereinafter referred as ‘Rules’), notified by the Central Government on October 17, 2019, which have been amended through the Foreign Exchange Management (Non-debt Instruments) (Second Amendment) Rules, 2024 vide S.O. 1361(E), dated March 14, 2024, enabling issuance of partly paid units to persons resident outside India by investment vehicles. Reference is also invited to Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019 and A.P. (DIR Series) Circular No. 7 dated May 21, 2024 , issued by the Reserve Bank. 2. In terms of Regulation 4(10) of the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019 , an investment vehicle which has issued its units to a person resident outside India shall file Form InVI within 30 days from the date of issue of units. In this connection, it is advised that investment vehicles may report issuances of partly paid units made prior to the date of this circular in Form InVI within 180 days from the date of this circular. No late submission fees shall be applicable for such reporting made within this period. However, issuances of partly paid units by investment vehicles on or after the date of this circular shall continue to be reported within 30 days, in accordance with the timelines specified under the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019 . 3. These directions will become operative with immediate effect. AD Category-I banks may bring the contents of this circular to the notice of their customers / constituents concerned. 4. 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 (Dr. Aditya Gaiha) Chief General Manager-In-Charge 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/2025-26/40 · issued 23 May 2025. The plain-English explanation above is BankPulse’s own independent summary.
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Worked example & action-note template

Example: if you are a Compliance officer at a bank this circular applies to (Category-I Authorised Dealer banks, Investment vehicles issuing partly paid units to non-residents, Non-resident investors in Indian investment vehicles), your first concrete step on “RBI eases reporting for partly paid units of investment vehicles” is: “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.” (RBI issued this 23 May 2025).

  1. Circular: RBI/2025-26/40 -- RBI eases reporting for partly paid units of investment vehicles
  2. Issued: 23 May 2025
  3. Action required: 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.
  4. Action required: Ensure new partly paid unit issuances on or after May 23, 2025, are reported within 30 days as per existing regulations.
  5. Action required: Update internal compliance checklists and training materials to reflect this circular's reporting timelines.
  6. Action required: Communicate the circular's contents to relevant customers and constituents promptly.
  7. Owner: ____________ Target date: ____________
  8. Board/committee approval needed? Y / N
  9. 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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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=12852&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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