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EMF & SMF Reporting

EMF & SMF Reporting

Foreign investments in India come with one non-negotiable responsibility: accurate reporting to RBI. That’s where the Entity Master Form (EMF) and Single Master Form (SMF) come in. They ensure your company’s foreign shareholding data is updated, compliant, and visible to the government on FIRMS.

Many businesses miss reporting timelines, assume their consultant has already done it, or misunderstand the filing category — and end up with compounding penalties. Let’s break it down so it feels manageable.

What is EMF?

EMF is a one-time reporting requirement where a company declares its complete foreign investment structure, percentage holdings, and investor details. Without an approved EMF, SMF filings won’t be allowed.

What is SMF?

SMF is used for ongoing reporting of foreign investment transactions — like share allotment, transfer, rights issue, bonus issue, buyback, or ESOP. It includes forms such as FC-GPR, FC-TRS, LLP(I), LLP(II), CN, DI, DRR etc.

Why it matters

  • Required under FEMA

  • Enables future foreign investment filings

  • Prevents late-fee exposure and compliance notices

  • Builds transparency for banking, investors, due diligence, and audits

What we help you with

  • EMF creation, verification, and submission on FIRMS

  • SMF filings for all types of FDI transactions

  • Documentation, valuation certificates, and shareholding reconciliation

  • Coordination with banks and AD Category-I branches

  • Rectification, resubmissions, and delayed reporting compliance

  • FEMA advisory before issuing or transferring shares

Typical documents required

  • COI, MoA, AoA

  • Shareholding pattern and cap table

  • Investor KYC and incorporation documents

  • FIRC, KYC from remitting bank, debit/credit advice

  • Board resolutions, share allotment documents, valuation report

Our process

  1. Understand the transaction and investment structure

  2. Review documents and identify gaps

  3. Prepare, validate, and upload forms

  4. Coordinate with bank/RBI if clarifications arise

  5. Close filing and share acknowledgment

Frequently Asked Questions

Yes, if you have any foreign shareholding, even 1 percent, EMF filing is compulsory.

 

Generally within 30 days of share allotment or transfer. Delays may attract late fees.

 

No. SMF access is granted only after EMF is successfully registered.

 

RBI may levy compounding penalties and request explanations from the company.

 

Yes. LLPs accepting foreign capital must report through the relevant SMF forms.