RBI compliance applies to a Pune company from the moment foreign money touches its share register, its loan book or its subsidiary ledger. If a non resident holds your shares, if you have drawn a loan from outside India, or if you own an entity abroad, you are a reporting entity under the Foreign Exchange Management Act. If your only cross border activity is invoicing an overseas customer and banking the proceeds, you are an exporter and none of this is due from you. Drawing that line first saves a lot of Pune founders a lot of worry.
Does RBI compliance actually apply to your Pune business?
Four situations put you in scope, and each one is easy to check against your own paperwork.
- A non resident individual, fund or parent company holds equity, preference shares or convertible instruments in your company.
- Shares in your company have moved between a resident and a non resident in either direction during the year.
- You have money in an overseas subsidiary, joint venture or step down entity that is still on the books.
- You have drawn an external commercial borrowing from a lender outside India, or from a foreign parent.
Knowing what is out of scope matters just as much. Selling software or consulting to an overseas customer is an export, reported through your bank and your GST returns, not through a FEMA form. A rupee loan from a resident director is a domestic transaction. A director carrying a foreign passport who is resident in India under FEMA creates no filing by himself. We test residency and instrument, never nationality.
What goes wrong when a Pune business gets the reporting wrong?
The first consequence is rarely a penalty order. It is your authorised dealer bank declining to certify the next inward remittance because the previous one was never reported, which stalls a tranche your investor has already wired. A delayed form then attracts a Late Submission Fee, computed on the amount involved and the length of the delay, and older breaches sit behind that in the compounding queue.
The expensive version shows up at diligence. A Baner lifestyle brand came to us with two angel cheques from an overseas investor unreported for fourteen months. The gap surfaced in a term sheet diligence pack, the round slipped a quarter, and the repair cost far more in time than in fees. Reporting is cheap while it is current and awkward once it is history.
Which dates and slabs govern these filings?
| Filing | What triggers it | Due by |
|---|---|---|
| FC-GPR | Shares allotted to a non resident investor | 30 days from the date of allotment |
| FC-TRS | Shares moving between a resident and a non resident | 60 days from the transfer |
| FLA return | Foreign investment or overseas investment on the books at 31 March | 15 July each year |
| Form ECB 2 | Any month in which an external commercial borrowing is outstanding | 7 working days from month end |
| Annual Performance Report | An overseas entity still held at the year end | 31 December each year |
Two of those catch people who believe they are finished. The FLA return falls every 15 July whether or not anything moved that year. The annual performance report keeps running for as long as the overseas entity is alive, and a dormant foreign subsidiary is still a live obligation.
How does the Maharashtra layer sit under a FEMA filing?
Nothing in a FEMA filing is settled at a counter in Pune. What is local is everything the filing has to agree with. Your GSTIN opens with 27, the Maharashtra state code, and your file sits with either a Maharashtra Goods and Services Tax Department officer on mahagst.gov.in or a Central GST officer. The state department splits Pune into six nodal divisions and allots jurisdiction by pincode, and the central side runs through two commissionerates, Pune-I and Pune-II. Two companies in one Kharadi building can answer to different officers.
The company law side has to line up too. A registered office in Pune district files with ROC Pune. The PAS-3 for a foreign investor's allotment and the FC-GPR for that same allotment must therefore carry one date, one share count and one price. Where they disagree, somebody eventually asks why.
State registrations do not pause because the money arrived from abroad. A Maharashtra company carries PTEC at ₹2,500 a year, due by 31 March. Payroll adds a separate PTRC. In Maharashtra a leave and licence agreement is compulsorily registrable under section 55 of the Maharashtra Rent Control Act 1999. So the registered office proof behind your FIRMS entity master should be that registered agreement, never a landlord's letter.
What does the work cost, and which documents does it need?
RBI compliance here starts at ₹15,000 for a standard reporting filing, and a clean engagement closes in 15 to 20 Days once the papers reach us. Price moves with the number of filings and the age of the delay. One current FC-GPR sits at the bottom of that range; three years of catch up with a compounding application sits at the top.
What we need from you is short and specific.
- The foreign inward remittance advice and the KYC report your authorised dealer bank issued for each receipt.
- Board and shareholder resolutions, the allotment record and the share certificate numbers for the issue.
- A valuation report from a merchant banker or chartered accountant supporting the price per share.
- The registered leave and licence agreement or ownership proof for your Pune registered office, with the company PAN and CIN.
Missing valuations and missing bank advices are what actually hold a filing up. Most of the rest we can rebuild from the MCA record.
Which Pune businesses are filing these forms?
- A lifestyle and D2C brand in Baner that took an angel cheque from an overseas investor and now owes an FC-GPR on the allotment and an FLA return every July.
- An IT services and delivery centre in Kharadi held by a foreign parent, where the yearly FLA return and any intra group share transfer drive the whole calendar.
- A Chakan auto component unit funded by an external commercial borrowing from its overseas group treasury, filing Form ECB 2 every month it stays drawn.
- A Hinjawadi software company that opened a subsidiary abroad to hold a customer contract and now owes an annual performance report each December.
How we run these filings for a Pune client
- We take a scoping call, list every cross border event since incorporation, and tell you which of them carry a form and which do not.
- We reconcile your bank advices, allotment records and MCA history, so the FEMA position and the ROC Pune position say the same thing before anything is submitted.
- We register or refresh your entity master on the FIRMS portal, prepare the form, and route it through your authorised dealer bank branch with valuation and KYC papers attached.
- We answer whatever the bank or RBI asks, chase the acknowledgement, and where a filing is late we compute the Late Submission Fee and settle it.
- We hand over a dated calendar for the July and December returns and the monthly borrowing return, so next year is a reminder instead of a scramble.
Why do Pune clients hand this to LegalX India?
Because this work sits across three desks and most teams own only one of them. Our CA and CS bench takes the FEMA form, the ROC Pune filing and the Maharashtra registrations together, which is why the numbers agree when somebody checks them. Ten years of doing it that way is the reason clients send us their diligence packs before their investors do. Our Pune office is at Yashwant Nagar, Near Bharatiya Samajseva, Yerwada, Pune 411006, and the engagement runs online from start to finish. For the wider picture first, read the national RBI compliance guide, then call us with your own dates.