What is Late Submission Fee LSF UNDER FEMA? How to Condone your reporting delays by paying LSFto RBI

What is Late Submission Fee (LSF) under FEMA?
FDI reporting compliances involve coordination with the authorised dealer bank and the remitter bank; and it also involves compliances under other Regulations, like Companies Act. Many Companies could not, therefore, make timely reporting under FEMA. These are only procedural lapses and the law only provided for adjudication process, or the company could have gone for compounding.


What is meant by Late Submission Fee (LSF)?
For the transactions undertaken on or after November 7, 2017, in case of reporting delays, the person/ entity responsible for filing the reports as provided in Part IV of the Master Direction on Reporting shall be liable for payment of Late Submission Fee (LSF). The payment of LSF is an additional option for regularising reporting delays without undergoing the compounding procedure.
Whether compounding option is available for reporting delays?


The payment of LSF is an additional facility for regularising reporting delays without undergoing the compounding procedure. However, this does not mean that the applicant cannot apply for compounding. Both options are available to the applicant for the transactions undertaken on or after November 7, 2017.








Contravention for non-issue / late issue/ non-transfer/ late transfer of capital instruments and other contraventions to be proceeded as per section 13 & 15 of FEMA,1999.


No claim for refund of LSF already deposited .


Delays in reporting made in respect of FDI in India would attract Late Submission Fee (LSF).


Option to regularize reporting delays without undergoing compounding procedure.
LSF will be calculated as per the following matrix.
Amount Involved in Reporting Rs LSF as % of as per the amount involved Maximum amount of LSF
Up to Rs 10 million 0.05% • Rs 1 million or
• 300% of the amount involved
More than Rs 1 Crore 0.15% Lower of
• Rs 10 million
• 300% of amount involved

• % of LSF will be doubled every 12 months.
• Minimum LSF will be Rs 100
Period of contravention shall be considered proportionally
(approximately rounded off to next higher month)* amount for 1 year
• Months will include Sunday / national holidays
• The date of reporting shall be the date of reporting to your banker provided all the documents are there.
• In case of incomplete form , the date of reporting will be taken as date on which complete form is filed.
• LSF will have to paid by way of DD in favour of RBI , regional office concerned.

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