FEMA 395(4)/2026-RB Reporting: Form LEC (IFI) for AD Cat-I Banks, FC-GPR, FC-TRS, and the FIRMS Portal

✍️ RebaseNest Team · Last updated 21 Jun 2026

·12 min read
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Assuming you are an NRI or OCI who buys Indian-listed equity through a stock broker on a repatriation basis, the question of who reports your trade to the Reserve Bank rarely comes up at the screen where you click Buy. It happens silently behind the broker, behind the depository, and behind the designated Authorised Dealer Category-I bank that handles your PIS account.

The 13 June 2026 amendment to FEMA Notification 395/2019, gazetted as FEMA 395(4)/2026-RB and listed on the Reserve Bank portal as Notification 13484, touches that silent layer in two distinct places. One is a substitution of Schedule III, which is purely about mode of payment and remittance of sale proceeds. The other is a substitution of sub-regulation (9) of Regulation 4, which introduces a bank-side reporting return called Form LEC (IFI) for individual foreign investors. The two are often conflated in popular reporting but they sit in different parts of the notification and they do different things.

This explainer walks the reporting layer carefully, separates the bank-side return from the entity-side and transfer-side FC-GPR and FC-TRS workflows that run on FIRMS, and flags the gaps the operational circular has not yet filled.

1. What the amendment actually contains

In the official RBI text of Notification 13484, the substituted Schedule III is titled "Investments by an individual person resident outside India including Non-Resident Indian (NRI) or Overseas Citizen of India (OCI) on repatriation basis" and contains two sub-headings: A. Mode of Payment and B. Remittance of sale proceeds. There is no "Reporting" sub-heading inside Schedule III. The mode-of-payment side has been covered in earlier posts in this series.

Separately, clause 3 of the same notification amends Regulation 4. In sub-regulation (9) of Regulation 4 of the principal regulations, the existing provision is substituted with the following text:

LEC (Individual Foreign Investor - IFI): The designated Authorised
Dealer Category I banks shall report to the Reserve Bank in Form
LEC (IFI) the purchase / transfer of equity instruments by an
individual person resident outside India including Non-Resident
Indians or Overseas Citizens of India on stock exchanges in India.

The two things to notice. First, LEC (IFI) is bank-side reporting, not investor-side filing. The duty is cast on the designated Authorised Dealer Category-I bank, not on the NRI or OCI. Second, "on stock exchanges in India" is the scope; primary issuance and off-market transfers are governed elsewhere.

The notification does not itself prescribe the format of Form LEC (IFI), the frequency, the portal, or the data fields. Those operational specifics typically follow in an AP DIR Series circular and a corresponding update to the Master Direction on Reporting under FEMA, 1999.

2. The Master Direction stack the amendment plugs into

Two RBI Master Directions matter for the reporting layer.

FED MD No.18/2015-16   Reporting under FEMA, 1999
                       (id=10202, updated as on 5 June 2026)

FED MD No.11/2017-18   Foreign Investment in India
                       (id=11200, updated up to 15 June 2026)

The Reporting Master Direction is where the FIRMS portal, the Single Master Form, the Entity Master, the FC-GPR clock, the FC-TRS clock, and the legacy bank-side returns sit. The Foreign Investment Master Direction is where the substantive rules of what NRI/OCI investment is permitted, the schedules, and the operational instructions to AD banks live. Both have current versions on the RBI portal updated within the past two weeks. Together they frame the operative context for Notification 13484.

The pre-amendment language on individual-foreign-investor reporting in the Reporting Master Direction already used a similar mechanism for NRI/OCI bank-side returns, distinct from the SMF family. The 13484 substitution replaces that with the IFI formulation. Until a fresh AP DIR Series circular folds the change into MD 18/2015-16, the operational portal and frequency are not in the public primary text.

3. The FIRMS portal: what it does and what it does not do

FIRMS is the Reserve Bank's foreign investment reporting portal. It hosts two layers.

Layer 1   Entity Master
          Indian entity (company, LLP, startup, AIF, REIT, etc.)
          expecting or holding foreign investment files this once,
          updates on changes.

Layer 2   Single Master Form (SMF)
          Transaction-level reporting by the Indian entity
          (or, for some flows, by the person resident outside India)
          for inflows, transfers, and instrument events.

The SMF family of forms in MD 18/2015-16 includes the following.

FC-GPR          Issue of equity instruments to a PROI
FC-TRS / FCTRS  Transfer of equity instruments between resident
                and non-resident, including stock-exchange transfers
                by a PROI
ESOP            Issue of employee stock options
DI              Downstream investment by an Indian company owned
                or controlled by non-residents
DRR             Depository Receipts Reporting (ADR / GDR issuance
                and conversion)
FDI-LLP (I)     Capital contribution into an LLP
FDI-LLP (II)    Disinvestment / transfer of LLP interest
InVI            Investment in an investment vehicle
CN              Convertible Note reporting by an Indian startup

Form LEC (IFI) under the substituted Regulation 4(9) is not part of this SMF family. It is a bank-side return filed by the designated Authorised Dealer Category-I bank directly to the Reserve Bank, separate from the entity-side FIRMS workflow. The portal for LEC (IFI) is not named in Notification 13484 itself, and the exact portal, frequency, and format sit in the operational layer of the Master Direction on Reporting and the AP DIR Series circulars, not in the regulation.

4. FC-GPR: the 30-day clock that is unchanged

FC-GPR is the workhorse of foreign investment reporting for an Indian company issuing equity instruments to a person resident outside India. Per the Master Direction on Reporting (FED MD 18/2015-16, current text):

Form FC-GPR is to be filed in the Single Master Form by an Indian
company that issues equity instruments to a person resident outside
India, not later than 30 days from the date of issue of the equity
instruments.

The 30-day clock starts from the date of issue, not the date of receipt of funds and not the date of share certificate or demat credit. Late filing attracts the Late Submission Fee structure prescribed by the RBI under the same Master Direction. The Authorised Dealer bank reviews and forwards the form; the regulatory filer is the issuing Indian company.

Notification 13484 does not touch FC-GPR.

5. FC-TRS: the 60-day clock and the stock-exchange overlay

FC-TRS sits in the SMF family for transfers of equity instruments between residents and persons resident outside India. The current Reporting Master Direction text:

Form FCTRS has to be filed with the AD bank within 60 days of
transfer of equity instruments or receipt / remittance of funds,
whichever is earlier.

The trigger is the earlier of two events, transfer or receipt/remittance of consideration, and the window is 60 days, not 30. For transfers on a recognised stock exchange by a person resident outside India, the Master Direction also casts the filing on the PROI rather than the resident counterparty. Operational handling is routed through the designated AD bank and the FIRMS process, but the legal duty under MD 18/2015-16 currently sits with the PROI.

The Regulation 4(9) substitution introduces Form LEC (IFI) as a separate AD-bank-side return for the same broad universe of transactions, i.e. purchase/transfer of equity instruments by an individual person resident outside India on stock exchanges in India. The notification text does not say LEC (IFI) replaces FC-TRS, and the Reporting Master Direction has not yet been updated to harmonise the two. The texts point to potentially overlapping reporting layers, but the public materials do not yet specify coexistence or sequencing for the same transaction. The position is expected to be clarified in an operational AP DIR Series circular.

6. Form LEC (IFI): what is explicit, what is open

From the substituted Regulation 4(9) text in Notification 13484, the following items are explicit:

Who reports        Designated AD Category-I banks
What is reported   Purchase / transfer of equity instruments
By whom            Individual person resident outside India,
                   including Non-Resident Indian and Overseas
                   Citizen of India
Where              Stock exchanges in India
To whom            Reserve Bank
Form               LEC (IFI)

Items the notification does not specify:

Portal             Not named in the notification text.
Frequency          Not specified.
Granularity        Per-trade vs aggregated not specified.
Data fields        Format of Form LEC (IFI) not annexed.
Effective date     The notification comes into force on the date of
                   publication in the Official Gazette (15 June 2026
                   per the RBI portal listing).
Late filing fee    Not specified in the notification.

The operational gaps would typically be filled by an AP DIR Series circular and a corresponding update to MD 18/2015-16. As of this writing, the existing AP DIR Series circulars listing on the RBI portal does not contain a 2026 circular specifically operationalising Form LEC (IFI). The relevant index page is linked in the Sources footer.

7. Who files what: the operational picture for an NRI or OCI investor

Action                              Filer            Form
Buy equity on a stock exchange      AD Cat-I bank    LEC (IFI)
  (on a basis covered by Schedule
   III); bank-side return
Sell equity on a stock exchange     AD Cat-I bank    LEC (IFI)
  (on a basis covered by Schedule
   III); bank-side return
Sell/transfer equity on a           PROI seller      FC-TRS via FIRMS
  recognised stock exchange         (operationally
  (transfer-side return)            via AD bank)
Transfer (off-market) equity        PROI seller      FC-TRS via FIRMS
  between a resident and a PROI     or resident
                                    counterparty
                                    per MD
Receive equity from a fresh issue   Indian company   FC-GPR via FIRMS
  by an Indian company (private
  placement / rights / preferential)
Annual position reporting           Indian company   FLA via FLAIR
  (received foreign investment)     or LLP receiving
                                    the foreign
                                    investment

The investor-facing observation: for stock-exchange purchases and sales on a repatriation basis under Schedule III, the substituted Regulation 4(9) places the new return on the bank, not on the customer. The customer's interaction with reporting is mediated by the designated Authorised Dealer Category-I bank, which already handles the PIS account, the inward remittance, the NRE-rupee account credit/debit, and the FEMA-side compliance.

Off-market transfers, primary issuance, and LLP/AIF events are governed by the SMF on FIRMS and are not displaced by the Regulation 4(9) substitution.

8. FLA and the annual layer

Form FLA is the Foreign Liabilities and Assets return filed by Indian companies, LLPs, and other reporting entities that hold inward FDI and/or have made overseas investment. It is filed annually through the RBI FLAIR portal by the Indian reporting entity, not by the AD bank and not by the foreign investor. FLA is an entity-side annual stock return, distinct from the transaction-level FIRMS layer and from the bank-side LEC layer.

The 13 June 2026 amendment does not touch FLA or the FLAIR portal.

9. The questions the operational circular will answer

The substituted Regulation 4(9) is regulation-level text. The operational rollout typically follows in the form of:

AP DIR Series circular   Operational instructions to AD banks
                         (portal, frequency, format, escalation)
MD 18/2015-16 update     Folds the new LEC (IFI) language into
                         the consolidated Reporting Master Direction
Form LEC (IFI) format    Annexed to the AP DIR circular or
                         published as a Reserve Bank notification

A useful set of questions to keep visible while the operational layer is awaited:

1. Does Form LEC (IFI) coexist with FC-TRS for stock-exchange
   trades, and if so, how are the obligations sequenced?
2. Is the filing per-trade, per-day, or per-period?
3. Is the portal the existing LEC channel, a FIRMS extension,
   or a new submission window?
4. What treatment applies to trades executed between
   15 June 2026 and the operational circular date?
5. How is any late-submission fee structure applied to
   bank-side LEC (IFI) filings?

None of these are answered by the primary text of Notification 13484. Drawing a confident operational answer before the AP DIR Series circular lands is reasoning beyond the primary source.

10. The clean operational picture

For NRIs and OCIs investing in Indian-listed equity on a repatriation basis under Schedule III as substituted by FEMA 395(4)/2026-RB:

Mode of payment           Schedule III A as substituted
                          (covered in earlier posts in this series)
Remittance of sale        Schedule III B as substituted
proceeds                  (covered in earlier posts in this series)
Stock-exchange purchase   Regulation 4(9) as substituted
or transfer reporting     Form LEC (IFI), bank-side filer
Off-market transfers      MD 18/2015-16, FC-TRS via FIRMS
Primary issuance          MD 18/2015-16, FC-GPR via FIRMS
Annual entity return      MD 18/2015-16, FLA via FLAIR

The reporting layer is unchanged for the investor's day-to-day interaction with the bank and the broker. The change is a new return obligation cast on the designated Authorised Dealer Category-I bank, with operational details pending.

A note on what this is. This article is one returnee's working notes, not personalised advice. Numbers age. Rules change. The only person who can sign off on your specific case is a qualified cross-border chartered accountant looking at your full facts. Use this as a checklist of questions to take to that conversation, not as the answer.

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