RBI: Submission requesting for resolution of issues faced by Industry while filing forms through FIRMS portal

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RBI: Submission requesting for resolution of issues faced by Industry while filing forms through FIRMS portal

Tejasvi

@tejasvi

September 6, 2021

Public Policy

366

As you may be aware, the Reserve Bank of India (RBI) recently introduced the Foreign Investment Reporting and Management System (FIRMS portal) to simplify foreign investment reporting by Indian entities by consolidating 9 different forms viz., FC-GPR Form, FC-TRS Form, LLP (I) Form, LLP (II) Form, CN Form, DRR Form, ESOP Form, DI Form and INVI Form, in one master form namely Single Master Form.

Based on feedback from Industry, we have highlighted the following issues faced by the Industry while undertaking compliances on FIRMS portal:

As per the current protocols, a company undertaking compliances through FIRMS portal is not allowed to file more than one form at a given point of time. For example, if the company has filed a form for reporting issue of shares after receiving foreign investment, the company would not be allowed to file another form unless the first form gets approved/ rejected by the RBI. This result in delay in undertaking compliances.
Moreover, in cases where RBI rejects a form for want of more information or any other reasons, the business entity is required to rectify and re-submit the form on the portal. In such cases, the date of filing of the revised form is considered as the original date of filing. For example, a company files a form on the 25th day and RBI responds with a request for more information on the 28th day. The company then resubmits the form on 32nd day, which is finally approved by RBI on 34th day. The FIRMS portal recognises 34th day as the date of filing of the form instead of 25th day. This results in penal consequences for the business for filing the form after the due date.

In this regard, we have requested RBI to:

Allow a company to file multiple forms simultaneously on the FIRMS portal.
The date of filing of the original form should be considered as the date on which the application was submitted by the user (and not the date on which the form is approved by RBI).

This will provide clarity to the Industry and will also facilitate ease of doing business. We will keep you posted on further developments in this regard.

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Tejasvi