eForm FC-4 Filing Services in India
Under the Foreign Exchange Management Act (FEMA), 1999 and the RBI Master Direction on Establishment of Offices in India by Foreign Entities, every foreign entity that has established a branch office, liaison office, or project office in India is required to file an Annual Activity Certificate (AAC) — commonly referred to as the eForm FC-4 — with the Reserve Bank of India through the Authorised Dealer (AD Category-I) bank. This annual filing confirms that the Indian office has operated within the activities permitted under its RBI or government approval during the financial year.
At N D Savla & Associates, our FEMA advisory team in Mumbai provides comprehensive eForm FC-4 filing services: preparing the Annual Activity Certificate from the audited accounts of the Indian office, obtaining the required Chartered Accountant certification, completing the submission through the AD bank, and advising on activity compliance for the upcoming year. We serve foreign companies across all major jurisdictions — from UK and US multinational corporations to UAE trading companies and Singapore technology firms with Indian offices.
The FC-4 (Annual Activity Certificate) is distinct from the eForm FC-3 filed under the Companies Act — FC-3 is an MCA filing of the foreign company's worldwide annual accounts, while FC-4 is a FEMA filing specific to the activities and transactions of the Indian office during the year. Both filings are mandatory and non-overlapping. Our team handles both as part of a complete annual compliance package for foreign company Indian establishments.
What Is eForm FC-4 (Annual Activity Certificate) and When Must It Be Filed?
The Annual Activity Certificate (AAC / eForm FC-4) is a structured annual report submitted by a foreign entity's Indian office to RBI through its AD bank, certifying that the Indian office has carried out only those activities that are permitted under the RBI or FIPB approval and has complied with FEMA regulations during the reporting year. The AAC is also a financial transparency tool — it includes a summary of expenses and transactions of the Indian office for the year.
Under the RBI Master Direction on Establishment of Branch Office / Liaison Office / Project Office, the Annual Activity Certificate must be filed by 30 September of the following financial year — for example, by 30 September 2026 for the financial year April 2025 to March 2026. The filing is made to the RBI Regional Office through the AD bank. For project offices, the AAC must be filed within 2 months of the project completion or 30 September annually, whichever is earlier.
Note: For liaison offices, which are prohibited from earning any revenue in India, the AAC is particularly important — it confirms that the liaison office did not undertake any commercial activity or generate revenue during the year, as doing so without prior RBI approval would be a FEMA violation.
Who Must File eForm FC-4?
Branch Offices of Foreign Companies
Foreign companies with RBI-approved branch offices in India — which can undertake trading and commercial activities specified in the approval — must file the AAC confirming that activities were limited to approved business and that all FEMA regulations were complied with. The AAC includes a summary of income from Indian operations.
Liaison Offices of Foreign Companies
Liaison offices — which can only represent the foreign parent company, undertake market research, and promote exports and imports, but cannot earn any revenue in India — must file the AAC confirming zero revenue and listing only the expenses incurred in liaison activities. The liaison office AAC is the most straightforward FC-4 but is also the most consequential if the office has inadvertently crossed into commercial activities.
Project Offices of Foreign Companies
Project offices established for execution of specific Indian projects — infrastructure, construction, power and similar — must file the AAC annually and also upon project completion. The project office AAC includes details of project progress, contracts executed, and compliance with the specific project approval conditions.
Foreign LLPs — LLPs with foreign partners — have their own separate FEMA annual reporting, specifically the Annual FLA Return and, for capital contribution receipts, FEMA Form 1 and FEMA Form 2. The FC-4 applies specifically to registered foreign company offices, not LLPs.
Historical Context: Annual Activity Reporting for Foreign Offices in India
The requirement for foreign entities to report their Indian office activities annually has been part of India's foreign exchange management framework since the FERA era. Under FERA (1973), foreign branch and liaison offices operated under strict RBI control — they required annual renewal of permission and comprehensive activity reporting to demonstrate continued compliance with their approval conditions.
FEMA (1999) liberalised the establishment framework significantly — RBI approval for branch and liaison offices became a one-time grant, subject to renewal conditions, rather than annual permission. However, FEMA retained and codified the annual reporting obligation in the form of the Annual Activity Certificate as a transparency and monitoring mechanism. The AAC replaced the more burdensome annual renewal application under FERA.
RBI has progressively standardised the AAC format and submission process. The current format — submitted through the AD bank as a structured report with a CA or CS certification — was developed through multiple RBI circulars and master directions from 2000 to the current Master Direction on Establishment of Offices in India by Foreign Entities. The introduction of FIRMS (Foreign Investment Reporting and Management System) for company FEMA filings has not yet been extended to FC-4 submissions — these are still made through the AD bank in physical or email format, though RBI has indicated digitisation of this process is under development.
eForm FC-4 Filing Process: Step-by-Step
- Accounts Compilation for Indian Office — We compile the Indian establishment's accounts for the reporting year, typically from the books maintained at the Indian office. For branch offices with revenue, we prepare a full income and expenditure statement. For liaison offices, we prepare the expense summary — salaries, rent, utilities, travel, communications — that constitutes the AAC's financial disclosure.
- Activity Compliance Review — We review the activities carried out by the Indian office during the year against the RBI approval conditions. This involves reviewing contracts, invoices, bank statements, and communications to ensure no activity fell outside the approved scope. Any potential compliance concern identified during this review is flagged and addressed before the AAC is filed.
- CA / CS Certification — The AAC must be certified by a Chartered Accountant or Company Secretary in practice. The certification states that the accounts are true and correct, that the Indian office has operated within its approved activities, and that all FEMA regulations have been complied with. N D Savla & Associates provides CA certification for all FC-4 filings.
- AAC Preparation — We prepare the complete AAC in RBI's prescribed format — covering the reporting period; type and nature of Indian office; details of the RBI approval (approval reference, approved activities, validity period); summary of activities undertaken; financial summary; number of employees; any remittances made or received; and a declaration of FEMA compliance.
- AD Bank Submission (by 30 September) — The completed and CA-certified AAC is submitted to the foreign company's AD bank in India by 30 September. The AD bank reviews the AAC, may ask clarifying questions, and forwards it to the RBI Regional Office. We follow up with the AD bank for confirmation of transmission to RBI.
- Coordination with FC-3 Filing — The FC-4 AAC and the FC-3 annual accounts filed with MCA are complementary — they cover the same financial year but go to different regulators. We coordinate both filings to ensure consistency of figures across the two regulatory submissions. See our eForm FC-3 Filing page for the Companies Act parallel compliance.
- RBI Office Renewal (if required) — For liaison offices, approved for an initial 3-year period and renewable for another 3 years, the AAC filing history is a key factor in RBI's renewal evaluation. A clean AAC filing record strengthens the renewal application. Our team manages the renewal application alongside the annual AAC filings.
Key Differences: eForm FC-3 vs eForm FC-4
The two annual filings are frequently confused. Both are mandatory, and neither substitutes for the other.
| Aspect | eForm FC-3 | eForm FC-4 (AAC) |
|---|
| Governing law | Companies Act, 2013 — Section 381 | FEMA, 1999 and RBI Master Direction |
| Filed with | Registrar of Companies, via MCA21 portal | RBI, through the AD Category-I bank |
| Content | Worldwide accounts of the foreign company | Indian office activities and FEMA compliance |
| Deadline | 6 months from the foreign company's financial year end | 30 September of the following financial year |
| Applies to | All foreign companies registered under Section 380 | Branch, liaison and project offices of foreign entities |
Companies with Indian subsidiaries, rather than branch or liaison offices, do not file FC-4. Their FEMA reporting is through FC-GPR and FC-TRS and annual FLA Returns.
Why Choose N D Savla & Associates for eForm FC-4 Filing in Mumbai?
FEMA Expertise for Foreign Establishments
Our team has advised liaison offices, branch offices, and project offices of foreign companies from multiple jurisdictions. We understand the nuances of each office type's permitted activities and the specific FEMA compliance implications.
Activity Compliance Pre-Check
Before filing the AAC, we review the year's activities against the approval conditions. This pre-check identifies any potential compliance gaps while there is still time to address them — rather than filing an AAC that could trigger RBI scrutiny.
CA Certification In-House
Our CA team provides the mandatory CA certification for the AAC as part of the filing service — no separate engagement required.
Dual FC-3 + FC-4 Package
We file both eForm FC-3 and FC-4 for foreign company clients in a coordinated annual compliance engagement — ensuring consistency, efficiency, and timely completion of both filings.
RBI Liaison Office Renewal Support
For liaison offices approaching their 3-year renewal dates, we provide RBI renewal applications supported by a clean AAC filing history — building the strongest possible case for continuation of the Indian office.
Frequently Asked Questions — eForm FC-4
What is the deadline for eForm FC-4 (Annual Activity Certificate)?
By 30 September of the following financial year — that is, by 30 September 2026 for the April 2025 to March 2026 financial year. For project offices, the AAC is also required within 2 months of project completion, regardless of the annual deadline.
What happens if a liaison office earns revenue in India?
A liaison office that earns revenue in India is in violation of FEMA — it has operated beyond its approved activities. Such violations must be disclosed in the AAC and may be reported to the Enforcement Directorate. The liaison office must either convert to a branch office, with RBI approval, or close. Our team advises liaison offices on activity boundaries and assists with conversion to branch office status when commercial activities are planned.
Is the FC-4 filing the same as the RBI Annual Return?
The FC-4 AAC is the primary annual FEMA reporting for Indian offices of foreign entities. It is submitted to RBI through the AD bank. This is distinct from the Annual Return (MGT-7) filed with MCA under the Companies Act — and also distinct from the FLA (Foreign Liabilities and Assets) Return filed by Indian companies with FDI. Foreign entity offices are subject to the FC-4 AAC; Indian companies with FDI are subject to the FLA Return. Both can be filed by N D Savla & Associates.
Can the AAC be filed by the Indian authorised representative of the foreign company?
Yes. The AAC must be signed by the authorised representative or principal officer of the Indian office. N D Savla & Associates can act as authorised representative for foreign companies and sign the AAC as part of our compliance service. The CA or CS certification is separate and provided by our practising CA.
What is the consequence of not filing FC-4?
Non-filing of the Annual Activity Certificate can result in RBI issuing a notice to the foreign company's AD bank; the AD bank being directed to freeze the Indian office's account; RBI initiating action to revoke the Indian office's approval; and FEMA violation proceedings. The continued operation of the Indian office without a current AAC is a persistent FEMA violation.
RBI Compliance Alert: Both eForm FC-3 (MCA) and FC-4 (RBI via AD bank, by 30 September) must be filed annually. Missing either filing puts the foreign company's Indian office at risk of regulatory action, account freezing, and approval revocation. Engage compliance advisors well before August each year.
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