Pursuant to the Foreign Exchange Management (Non-Debt Instruments) Rules, 2019 (‘NDI Rules'), investment vehicles may issue partly paid units to persons resident outside India. Furthermore, pursuant to the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019, an investment vehicle which has issued units to a person resident outside India is required to file Form InVI within 30 days from the date of issue. The RBI has now, by way of a Circular dated May 23, 2025, issued a clarification that investment vehicles issuing partly paid units to persons resident outside India prior to the date of the Circular, will be required to report such issuances in Form InVI within 180 days from the date of the Circular without any late submission fee. However, this is a one-time relaxation for past issuances and all issuances of partly paid units made after the date of the Circular must be made within 30 days of the date of such issue.
Originally published 29 July 2025
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