RBI FIRMS portal — complete guide to uploading your APR

For Indian companies with overseas subsidiaries, the RBI's FIRMS portal is where APR filing India happens. But the portal is not always intuitive — and a single data entry error, missing document, or wrong section completion can result in your AD bank returning the filing for correction, sometimes just days before the December 31 deadline.

This guide walks through the complete FIRMS portal APR upload process — from Entity Master verification through to acknowledgement receipt — with specific attention to the sections where errors are most common and the documents that must be in place before you begin.

What Is the FIRMS Portal and Why APR Goes Through It

The Foreign Investment Reporting and Management System (FIRMS) portal — accessible at firms.rbi.org.in — is the RBI's unified online platform for all foreign investment reporting under FEMA. It handles inward FDI reporting (FC-GPR, FC-TRS), outward ODI reporting, and the Annual Performance Report for overseas investments.

The APR is not filed directly by the Indian company on the FIRMS portal. The process involves the Indian company preparing the APR, submitting it to their Authorised Dealer Category-I (AD Cat-I) bank, and the AD bank uploading it to FIRMS on the company's behalf after verifying the submission.

This two-step process — company to AD bank, AD bank to FIRMS — means preparation errors are caught at the AD bank level, but only after the AD bank has reviewed the submission. A rejection at this stage with less than a week to the December 31 deadline is a genuine operational crisis. Understanding every requirement in advance prevents it.

Before You Start: Entity Master Verification

The Entity Master is the foundational record on the FIRMS portal — it captures the details of the overseas entity in which the Indian party has made ODI. Every APR is associated with the Entity Master of the relevant overseas entity.

Before submitting the APR, verify the Entity Master is:

• Created — if this is the first APR for a newly incorporated overseas entity, the Entity Master must be created first through the AD bank (this is typically done when the original ODI remittance is made via Form FC).

• Accurate — company name, country of incorporation, type (JV or WOS), nature of business, and the Unique Identification Number (UIN) assigned by the RBI must all match current records

• Updated — if there have been changes to the overseas entity's structure (name change, activity change, step-down subsidiary additions) since the last filing, the Entity Master must be updated before the APR is submitted

The UIN is the single most important reference number in the APR process. Every submission is keyed to the UIN. If the UIN on your APR does not match the FIRMS Entity Master record, the AD bank cannot process the filing.

Document Checklist Before You Begin

Prepare all of the following before submitting the APR package to your AD bank:

For the overseas entity audit: The audited financials must be prepared under the applicable accounting standard of the overseas jurisdiction — US GAAP for US entities, UK FRS 102 or IFRS for UK entities, Singapore FRS for Singapore entities. The audit must be conducted by an auditor licensed in that jurisdiction. An Indian CA cannot sign the audit opinion for a US LLC or UK Ltd. This is one of the most frequent bottlenecks in overseas subsidiary audit compliance — Indian companies discover in November that their US subsidiary's audit is not complete because they engaged an Indian CA to do it.

Step-by-Step: How the APR Is Filed on FIRMS

Step 1 — Prepare Form ODI Part II

Form ODI Part II is the statutory APR form. It is available on the RBI website and through your AD bank. The form has several sections — each must be completed accurately before submission to the AD bank.

Key sections of Form ODI Part II:

Part A — Details of the overseas entity:

• Name, country, type of entity (JV/WOS), date of incorporation

• UIN assigned by RBI

• Nature of business activities

• Reporting period (financial year of the overseas entity)

Part B — Financial data:

• Total assets and net worth of the overseas entity

• Turnover for the year

• Net profit or loss after tax

• Retained earnings as at year end

• Whether the entity is operational, dormant, or under winding up

Part C — Dividend and repatriation details:

• Dividends declared by the overseas entity during the year

• Amount remitted to the Indian party and date of receipt

• Other dues repatriated (management fees, royalties, loan repayments)

• CA certification that all dues have been repatriated within 90 days

Part D — Structural changes:

• New step-down subsidiaries incorporated or acquired

• Step-down subsidiaries wound up or transferred

• Changes in shareholding pattern of the overseas entity or its step-down subsidiaries

• New financial commitments (loans, guarantees) by the Indian party

Part E — Declaration and certification:

• Authorised signatory of the Indian company

• Date and place of signing

• CA/statutory auditor certification where required

Step 2 — Internal Review Before Submission to AD Bank

Before taking the completed Form ODI Part II to the AD bank, the Indian company's finance team should verify:

• All financial figures match the overseas entity's audited statements — no rounding errors, no mismatched currencies

• Dividends reported in Part C match actual bank credit advices in the Indian company's bank statements

• Step-down subsidiary changes in Part D are complete — omitting an SDS formation is a FEMA violation

• The CA certificate covers the entire reporting period and is dated after the financial year close

• The UIN on the form matches the FIRMS Entity Master

Step 3 — Submit to Authorised Dealer Bank

The completed Form ODI Part II, along with the full document package, is submitted to the designated AD Cat-I bank. For most Indian companies, this is the bank through which the original ODI remittance was made — the "designated AD bank" associated with the UIN.

What the AD bank does:

• Reviews the form for completeness and consistency

• Verifies the UIN against the FIRMS Entity Master

• Checks that audited financials are attached (where mandatory)

• Verifies that the CA repatriation certificate is in order

• Raises queries if any section is incomplete or inconsistent

AD bank review time: Most AD banks complete their review within 3–7 working days. For companies submitting in mid-December, this timeline matters critically. Submitting to the AD bank by December 15 at the latest ensures time for corrections if the bank raises queries before the December 31 deadline.

Step 4 — AD Bank Uploads to FIRMS

Once the AD bank is satisfied with the submission, it logs into the FIRMS portal, navigates to the ODI module, selects the Annual Performance Report section, and uploads the APR data linked to the company's UIN.

The FIRMS portal captures:

• Entity details from the Entity Master

• Financial data entered from Form ODI Part II

• Scanned attachments (audited financials, CA certificate, board resolution)

The AD bank maker enters the data; the AD bank checker verifies and authorises the upload. This maker-checker process within the AD bank is an internal control — not visible to the Indian company but part of the RBI's FIRMS submission workflow.

Step 5 — Receive Acknowledgement

After successful upload, the FIRMS portal generates an acknowledgement receipt with a submission reference number. The AD bank provides this to the Indian company.

Store the acknowledgement safely. It is the primary proof of APR compliance and is requested in several situations:

• When making a subsequent ODI remittance

• When setting up a new overseas entity

• During RBI inspections or AD bank KYC reviews

• During investor due diligence (Series A, B, pre-IPO)

Common Reasons APR Submissions Are Rejected or Returned

Understanding the most frequent rejection reasons saves weeks of back-and-forth:

1. Audited financials not attached or auditor not locally licensed The most common rejection. If the Indian company has submitted management accounts instead of audited statements, or if the auditor's report is signed by an Indian CA for a foreign entity, the AD bank will return the submission. The overseas audit must be completed by a US CPA (for US entities), UK ICAEW auditor (for UK entities), or the appropriate locally licensed auditor.

2. Mismatch between Form ODI Part II financial figures and attached financials If the net worth, turnover, or profit/loss figures in the form do not exactly match the attached audited statements — including currency differences — the AD bank will return the form for reconciliation.

3. Missing CA repatriation certificate The certification that all dues have been repatriated within 90 days is a mandatory attachment. A signed Form ODI Part II without this certificate cannot be processed.

4. Step-down subsidiary changes not disclosed If a step-down subsidiary was incorporated or wound up during the year and Part D is left blank or incomplete, the AD bank FEMA compliance team will return the submission.

5. Previous year APR acknowledgement not provided Most AD banks require the prior year's APR acknowledgement as part of the current year submission package — to confirm there are no pending gaps in the compliance chain.

6. UIN mismatch or Entity Master not updated If the Entity Master was not updated after a corporate action (name change, step-down subsidiary addition), the FIRMS upload will fail at the portal level.

Timing: The December 31 Deadline Is a Hard Stop

The RBI's December 31 deadline for APR filing has no official extension mechanism. Unlike some regulatory filings where extensions are granted routinely, APR does not have a grace period. A filing submitted to the AD bank on December 28 — too late for the AD bank to complete its review and upload before December 31 — constitutes a late filing, and LSF of ₹7,500 applies automatically.

Target dates for a clean December 31 compliance:

How Accorp Partners Manages the Complete APR Filing Process

Accorp Partners is a US CPA and CA (India) firm providing end-to-end APR filing for Indian companies with overseas subsidiaries — from the overseas audit through FIRMS portal submission.

Our services include:

• Overseas subsidiary audit — licensed US CPA audit for US entities, UK ICAEW audit for UK entities, Singapore ISCA for Singapore entities — producing APR-ready audited financials

• Form ODI Part II preparation — complete APR form preparation, all parts including step-down subsidiary disclosures

• CA repatriation certificate — certifying dues repatriated within 90 days as required

• AD bank coordination — managing the AD bank submission and query resolution process

• Entity Master verification — confirming UIN accuracy and updating Entity Master where needed before submission

• FIRMS portal follow-up — tracking the AD bank upload and obtaining the acknowledgement receipt

• Back-year APR filing — LSF payments and FEMA compounding for prior-year non-compliance

Fixed-fee APR audit and filing. Managed entirely by our team — the Indian company's finance team provides the overseas entity's financials and answers our queries. We handle the rest.

Also Read: Why UK Subsidiaries With Dormant Accounts Still Need Auditor Certification for APR Under FEMA