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FEMA COMPLIANCE CALENDAR 2026-27

The FEMA compliance calendar for FY 2026-27 rests on a monthly ECB-2 rhythm, two touchpoints for the Foreign Liabilities and Assets (FLA) Return in July and September, the Annual Activity Certificate (AAC) in September, and the Overseas Direct Investment Annual Performance Report (ODI APR) in December. This calendar covers every recurring external-sector filing for entities with ECB, FDI, or ODI exposure through March 2027.

23 Jul 20265 min read

FEMA Compliance Calendar — FY 2026-27

The FEMA compliance calendar for FY 2026-27 rests on a monthly ECB-2 rhythm, two touchpoints for the Foreign Liabilities and Assets (FLA) Return in July and September, the Annual Activity Certificate (AAC) in September, and the Overseas Direct Investment Annual Performance Report (ODI APR) in December. Each monthly ECB-2 return is due by the 7th for the preceding month, starting with March 2026 in April and running through February 2027 in March. The annual filings — FLA, AAC, and ODI APR — all close the books for FY 2025-26 and fall at defined intervals through the year. This calendar covers every recurring external-sector filing for entities with ECB, FDI, or ODI exposure through March 2027.

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https://ktmckzwwwtfvsphgktxq.supabase.co/storage/v1/object/public/media/2026/1784778038227-fema.pdf

07 April 2026 (Tuesday)

  • ECB-2 Return for March, 2026 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

07 May 2026 (Thursday)

  • ECB-2 Return for April, 2026 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

07 June 2026 (Sunday)

  • ECB-2 Return for May, 2026 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

07 July 2026 (Tuesday)

  • ECB-2 Return for June, 2026 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

15 July 2026 (Wednesday)

  • Annual Return on Foreign Liabilities and Assets (FLA Return) for FY 2025-26 — based on unaudited financials, to be filed on or before 15th July. Applicability: Indian companies/LLPs/entities that have received FDI and/or made ODI in the previous year, including current year. Reference: Regulation 3.4, FEMA (Mode of Payment and Reporting of Non-Debt Instruments) Regulations 2019

07 August 2026 (Friday)

  • ECB-2 Return for July, 2026 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

07 September 2026 (Monday)

  • ECB-2 Return for August, 2026 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

30 September 2026 (Wednesday)

  • Annual Return on Foreign Liabilities and Assets (FLA Return) for FY 2025-26 — revised, based on audited financials, if audit completed after 15th July. Applicability: Same entities where statutory audit is completed after the July filing. Reference: Regulation 3.4, FEMA (Mode of Payment and Reporting of Non-Debt Instruments) Regulations 2019

  • Annual Activity Certificate (AAC) for FY 2025-26. Applicability: Indian companies/LLPs with FDI; WOS/JV of foreign companies; entities under conditional FDI approval (NBFC, AMC/AIF/PMS, BPO/ITES, real estate, minimum-capitalisation sectors). Reference: FEMA (Non-Debt Instruments) Rules 2019 r.w. RBI Master Direction on Reporting

07 October 2026 (Wednesday)

  • ECB-2 Return for September, 2026 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

07 November 2026 (Saturday)

  • ECB-2 Return for October, 2026 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

07 December 2026 (Monday)

  • ECB-2 Return for November, 2026 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

31 December 2026 (Thursday)

  • Annual Performance Report (APR) — Form ODI Part II, for FY 2025-26. Applicability: Indian Party/Resident Individual with Overseas Direct Investment, for each JV/WOS outside India. Reference: FEMA (Overseas Investment) Rules 2022 r.w. Master Direction — Overseas Investment

07 January 2027 (Thursday)

  • ECB-2 Return for December, 2026 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

07 February 2027 (Sunday)

  • ECB-2 Return for January, 2027 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

07 March 2027 (Sunday)

  • ECB-2 Return for February, 2027 (External Commercial Borrowings). Applicability: Borrowers having outstanding External Commercial Borrowings. Reference: Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations

How We Help

The FEMA calendar runs a tight monthly ECB-2 cadence alongside three critical annual filings — the FLA Return (with its July-September dual filing window), the Annual Activity Certificate in September, and the ODI APR in December. Missing any of these can delay compounding applications, trigger non-compliance flags with the AD bank, or disrupt future inbound and outbound investment reporting. At Anuj Desai & Associates, we track every entity's ECB, FDI, and ODI profile, prepare the returns and certificates from validated financial and transactional data, and lodge them directly with the RBI portal through the authorised dealer bank. If you want the entire external-sector reporting cycle managed, reach out to our FEMA compliance desk.

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