What APR reporting covers
Indian entities that have made an Overseas Direct Investment — setting up or investing in a foreign subsidiary or joint venture — are required to file an Annual Performance Report reporting on the financial performance and status of that overseas entity, as part of ongoing FEMA compliance for outbound investment.
Who needs to file
Any Indian party holding an ODI investment (equity in a foreign JV or wholly-owned subsidiary) as of the relevant reporting date generally has an APR obligation, continuing each year for as long as the investment is held — similar in spirit to the FLA return obligation for inward investment.
What the report generally requires
- Financial statements or summary financial data of the overseas entity for the relevant period
- Confirmation of the Indian party's continuing shareholding/investment in the foreign entity
- Details of any changes to the investment during the year
Common compliance gaps
- Missing the filing entirely because the overseas entity's own financials aren't finalised in time, when a provisional filing option or extension should be pursued instead
- Not filing in a year where the overseas entity has become dormant, incorrectly assuming the obligation lapses if the entity isn't actively trading
- Overlooking APR obligations for smaller or older overseas investments that predate current compliance processes
Why staying current matters
Consistent, on-time APR filing is one of the things regulators check when a business seeks approval for further overseas investment or other FEMA-related transactions — a poor compliance history here can complicate future outbound investment plans, beyond just the compounding exposure for the missed filings themselves.
Related Reading
Have a question about your specific situation?
Talk to Our Team →