ODI Compliance: Annual Performance Report (APR) Filing Explained
Once an Indian entity invests abroad, the compliance does not end with the remittance. Every year, it must report the performance of its foreign investment to RBI through the Annual Performance Report (APR). Missing this is one of the most common FEMA defaults. This guide explains APR filing under ODI — who must file, the due date, the form, and the penalties.
What Is the Annual Performance Report (APR)?
The APR is an annual filing that updates RBI on the financial position and performance of each foreign entity in which an Indian person resident holds an Overseas Direct Investment. It ensures continuous oversight of outbound investments under the FEMA ODI framework.
Who Must File the APR?
Every Indian entity or resident individual that has made an ODI and holds a Unique Identification Number (UIN) must file an APR for each foreign entity, as long as the investment continues. This applies whether the investment was through the automatic or approval route. See our complete ODI guide.
Due Date for APR
The APR must be filed by 31 December each year, based on the audited (or, where permitted, unaudited) financial statements of the foreign entity for the preceding accounting period. Where audited accounts are not yet available, the rules allow filing based on unaudited accounts under certain conditions.
What Information the APR Contains
- Financial details of the foreign entity (capital, reserves, profit/loss).
- The Indian party’s stake and any changes during the year.
- Repatriations received (dividend, royalty, fees, loan repayments).
- Net worth and the value of the investment.
How the APR Is Filed
The APR is filed through the AD bank on the RBI portal, certified as required. Where there are multiple Indian investors in the same foreign entity, the entity with the largest stake typically files. The filing is linked to the foreign entity’s UIN allotted at the time of Form FC reporting.
Consequences of Non-Filing
Failure to file the APR is a contravention of FEMA. It can:
- Block further financial commitments to the foreign entity.
- Hold up other ODI transactions and remittances.
- Attract compounding proceedings and penalties.
APR Compliance Checklist
| Item | Detail |
|---|---|
| Who files | Indian party/resident with ODI & UIN |
| Due date | 31 December each year |
| Based on | Foreign entity’s financial statements |
| Filed via | AD bank / RBI portal |
| Non-filing | FEMA contravention |
Frequently Asked Questions
When is the APR due?
By 31 December each year, based on the foreign entity’s latest financial statements.
Who files when there are multiple Indian investors?
Generally the investor with the largest stake files the APR for the foreign entity.
Can APR be filed on unaudited accounts?
In certain cases, yes — the rules permit it where audited accounts are unavailable, subject to conditions.
What happens if I miss it?
It is a FEMA contravention that can block further transactions and lead to compounding penalties.
Never Miss an APR Deadline
S. Choudhary & Co. manages ODI reporting, including Form FC, UIN, and annual APR filings. Explore our Overseas Direct Investment services or call +91 90248 28295 · sushil@sushilchoudhary.com.
