RBI publishes circular on reporting of issuance of partly paid units by investment vehicles on FIRMS portal

The Reserve Bank of India (RBI) had amended the Foreign Exchange Management (Non-debt Instruments) Rules, 2019 vide notification dated March 14, 2024, enabling issuance of partly paid units to persons resident outside India by investment vehicles. Further as per Regulation 4(10) of the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations (Reporting Regulations), an investment vehicle which has issued its units to a person resident outside India shall file Form InVI within 30 days from the date of issue of units.

In this backdrop the RBI has, vide circular dated May 23, 2025, issued guidelines on the reporting of issuance of partly paid units by investment vehicles on the Foreign Investment Reporting and Management System (FIRMS) Portal (Reporting Circular).

As per the Reporting Circular, the RBI has inter alia directed that:

• For reporting of issuances prior to the date of the Reporting Circular, the investment vehicles may report issuances of partly paid units in Form InVI within 180 days from the date of the Reporting Circular. No late submission fees shall be applicable for such reporting made within this period.
• The reporting of issuances on or after the date of the Reporting Circular, shall continue to be reported within 30 days, in accordance with the timelines specified under the Reporting Regulations.

For more details, kindly refer to the Reporting Circular, available by clicking on this link.