/ FEMA Form Checklist · Updated 2026-10-22

Form ODI Part II (APR) Annual Report India 2026 Due 31 Dec, overseas investment annual filing.

Form ODI Part II (APR - Annual Performance Report) is annual FEMA filing by Indian company for its overseas direct investment (ODI): due 31 December each year for FY ended March. Covers overseas subsidiary performance, dividend repatriation, change in investment. Non-filing attracts FEMA Section 13 compounding. Here's the complete 2026 compliance alert.

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Written by CA Durgesh Chavda

Chartered Accountant (ICAI) · Founder, Bharat Quantum Prospera · US incorporation, India-US DTAA, FEMA ODI, NRI taxation, cross-border structuring · LinkedIn

/ Who files + when

The core rule.

Any Indian company that has made overseas direct investment (ODI) in foreign subsidiary / JV / branch.
Must file APR annually by 31 December for FY ended previous March.
So APR for FY 2025-26 (ended March 2026) due by 31 December 2026.
Via FIRMS portal (RBI) through AD-I category bank.
Non-filing: FEMA Section 13 compounding.

/ What's in APR

The data.

Foreign subsidiary / JV identification: name, country, incorporation details, business activity.
Share capital + Indian company's ownership %.
Financial highlights: revenue + profit + net worth (audited foreign financials basis).
Dividend received by Indian company during year (if any).
Changes in investment: additions / disposal / dilution during year.
Foreign subsidiary's own compliance status + relevant local filings.
Any pending disputes / litigation.

/ Common APR issues

Where companies trip.

Multi-year non-filing - cleaner via one consolidated FEMA compounding.
Foreign subsidiary audit not completed by December - APR filing delayed. Provisional APR acceptable.
Dividend received not reflected in Indian company Form 15CA / 15CB coordination.
Change of foreign subsidiary name / registered office not updated in APR.
Foreign subsidiary wound up but Indian company didn't file wind-up ODI Form - continuing APR obligation misreported.

Last updated: 2026-10-22.

/ Ready when you are

Form ODI Part II (APR) due 31 December 2026.

Annual filing for Indian parent of foreign subsidiary. BQP: foreign subsidiary data + APR drafting + FIRMS filing + past missed APR compounding.

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FAQ

Common questions, answered.

When is Form ODI Part II (APR) due?

31 December each year for FY ended previous March. So APR for FY 2025-26 due by 31 December 2026.

What if foreign subsidiary audit not complete?

File provisional APR with unaudited numbers; file revised APR within 30 days of foreign subsidiary audit completion. Acceptable practice; don't delay provisional filing waiting for audit.

What's the penalty for missed APR?

FEMA Section 13 compounding: typically INR 10,000-50,000 per missed year. Multi-year missed APRs can be consolidated in single compounding application.

Does BQP file APR for Indian parent of foreign subsidiary?

Yes - standard annual service. Foreign subsidiary financial data collection + APR drafting + FIRMS portal filing + Form 15CA/15CB coordination for dividend repatriation. Also compounding of past missed APRs. WhatsApp +91 78018 87130.