RBI FIRMS Portal Update: Relief for Bulk Form DI Filings - Late Submission Fee (LSF)

The Reserve Bank of India (RBI) has upgraded its FIRMS (Foreign Investment Reporting and Management System) portal to enable bulk filing of Form DI for multiple securities of a single investee entity.
While a new portal was introduced to simplify foreign investment reporting, it initially led to the unintended levy of the Late Submission Fee (LSF) in certain cases. RBI has now simplified the LSF levy for the reporting entities.

This article explains the issue, RBI’s clarification, and its implications for companies and compliance professionals.

What Changed in the RBI FIRMS Portal?

Earlier, Form DI filings were largely transaction-specific, requiring multiple submissions for staggered or large allotments. Recognising the compliance burden, RBI upgraded the FIRMS portal where bulk reporting under a single Form DI for one investee company.
Objectives of the FIRMS upgrade:

• Repetitive Form DI filings will be reduced
• Streamline foreign investment reporting under FEMA
• Improve accuracy & compliance efficiency

The change will ease the compliance burden for the entities who made the multiple Investment in the same securities.

Late Submission Fee (LSF) for Form DI – Overview

Under RBI regulations, Late Submission Fee (LSF) will be levied if the reporting is delayed
LSF structure:

• Fixed component: ₹7,500
• Variable component: Based on the period of delay

LSF intends to encourage the timely reporting of foreign investment transactions.

Issue Faced in Bulk Form DI Filings

Following the portal upgrade, several companies filed bulk Form DI covering multiple securities under one submission. However, the FIRMS portal initially:

• Levied the fixed LSF of ₹7,500 per security
• Multiple LSF charges for a single Form DI
• LSF levied disproportionately

Example:
If one delayed Form DI covered 5 securities, LSF was charged as:
₹7,500 × 5 = ₹37,500
— despite there being only one Form DI and one delayed filing.

RBI Clarification on LSF for Bulk Form DI

Since LSF has become a burden for the entities, RBI reviewed the matter and issued a clarification:
For bulk filings under a single Form DI pertaining to one investee entity, only one fixed component of LSF will be levied.
Impact of the clarification:

• One Form DI = one fixed LSF
• Multiple fixed fees will not be levied for a bulk filing
• Variable LSF continues to depend on delay period

Refund of Excess LSF Paid

Pursuant to this clarification, RBI has:

• Refunded excess LSF collected earlier (Specifically the Fixed Component)
• Credited refunds to the reporting entities
• Restored fairness and consistency in FEMA compliance

The entities have positively received this relief.

Key Takeaways for Companies & Professionals

• Bulk filing under Form DI is permitted on the FIRMS portal
• Only one fixed LSF of ₹7,500 applies per delayed Form DI
• Mutplie Fixed LSF do not apply for bulk fling
• Excess LSF already paid has been refunded
• Timely Form DI filing remains critical to avoid LSF

How KDP Can Assist

Foreign investment reporting under FEMA requires both technical accuracy and procedural clarity. At Kamdar Desai & Patel LLP, we regularly assist Indian companies, foreign investors, AIFs, and startups with:

• DI Applicability under different scenarios
• Form DI and necessary registration
• Foreign investment structuring and reporting
• Regulatory clarifications and representation support

Conclusion:

The RBI’s clarification demonstrates a practical and responsive regulatory approach. While the FIRMS portal upgrade significantly improves reporting efficiency, this development provides much-needed clarity on LSF applicability for bulk Form DI filings.

For businesses dealing with foreign investment compliance in India, this update offers both financial relief and regulatory certainty. For expert assistance on Form DI filings, LSF applicability, and foreign investment compliance under FEMA, feel free to reach out to us at enquire@kdpaccountants.com.

Disclaimer:

The above note is subject to further study and clarification. This note does not form an opinion from our end and before taking any decision based on the above, it is recommended to consult our experts on the subject. Kamdar, Desai & Patel will not be liable for any damages (including, without limitation, damages for loss of business projects, or loss of profits) arising in contract, tort, or otherwise from the use of or inability to use this article or any of its contents, or from any action taken (or refrained from being taken) as a result of using this article or any such contents.