By Surbhi Kejriwal, Pranay Bagdi, Parag Bhide

On 7 June 2018, the Reserve Bank of India (RBI) notified changes to the existing reporting requirements in respect of foreign investments in India with the objective to consolidate and integrate all existing reporting for, inter alia, issue of shares and transfer
of shares in a Single Master Form (SMF) online.

All Indian Entities with foreign investment will need to collate and submit the information requested to the RBI within a short timeframe. While this may be easier for entities with direct foreign investment, entities will also have to assess and collate information on indirect foreign investment. It is unclear whether this one-time reporting will result in RBI regularising any past reporting lapses by Indian Entities. As an immediate next step, all Indian entities with foreign investment – both, direct and indirect have to take steps for meeting the regulatory expectations. The extent of RBI’s oversight in view of the additional disclosures remains to be seen.