APR (Annual Performance Report): Eligibility, Exemptions, and Key Requirements

• Auditing and Assurance
• ||
• October 24, 2025

Have you filed your Annual Performance Report yet? (December 31) The deadline is approaching.

If you are an Indian resident or an entity that has made investments abroad, then you must be aware of the requirement to submit the APR to the RBI (Reserve Bank of India). The RBI mandates the submission of this report to be certified by a Statutory Auditor / Chartered Accountant before the deadline to avoid a late submission fee or compliance issues.

If you are not familiar with this requirement, don’t worry- you are in the right place. In this article, we will cover everything you need to know about APR filings.

What is APR?

APR stands for the Annual Performance Report. APR is a progress report about your investment, which you made in a foreign country, either through a Joint Venture (JV) or a Wholly Owned Subsidiary (WoS).  

It provides details such as:

• The financial performance of a foreign company (like net profit, net worth, etc.)

• Repatriation from the foreign entity

• Capital structure as of the last day of the accounting year of the foreign entity

Who needs to file an APR?

The APR report is required to be submitted by individuals who are residents of India and by Indian entities acquiring equity/making capital investment in any foreign entity, known as ODI (Overseas Direct Investment).

In simple terms, the above line suggests the applicability of filing an APR: if you are an Indian resident/Indian entity and made an investment abroad, you must file the APR report to the RBI (Reserve Bank of India).

An important thing to remember here is that you must file an APR for each foreign entity/company you have invested in each year, as long as the investment continues and the person remains a resident of India.

Exemption

If you are investing in a foreign entity, you need to file an APR, but there are conditions that exempt you from filing it.

Below are the situations in which you do not need to file an APR:

Deadline for Submission of APR

The deadline to submit the APR is December 31 for each year, as the accounting year of the foreign entity typically ends on this date. Therefore, the APR shall be submitted by December 31 of the subsequent year of the event.

In simple terms, if you invested in the previous year, you need to file the APR this year.

Audited Financial Statements

APR shall be based on the audited financial statements; that’s why, after your foreign company (JV/WOS) finishes preparing its audited accounts (yearly financial statements approved in the country where it is located), you must file out and submit the APR report.

This report should be based on the audited financial statement as explained in the above paragraph. Still, if you do not control the foreign company, and the foreign country’s law does not require that company to get its accounts audited. You are allowed to file the APR using unaudited financial statements instead.

These unaudited statements must be certified by:

• The statutory auditor of the Indian company (if it has one), or

• A chartered accountant (if the Indian investor is an individual or the company doesn’t have a statutory auditor)

In short, if you don’t control the foreign company and it’s not required to be audited abroad, you can file the APR with unaudited accounts, as long as they are verified by a CA or your auditor in India.

Key Requirements to File APR as per RBI

Here are certain requirements, or we can say important documents, which you need to maintain to file an APR:

Why is APR necessary?

As we know, in India, there is a law for the management of all foreign exchange transactions, called the Foreign Exchange and Management Act (FEMA Act 1999), which applies to all branches, offices, and agencies outside India owned or controlled by a person resident in India.

Even if an Indian person or company operates outside India, they must still follow Indian foreign exchange laws (like FEMA). If they break the rules abroad, they can still be held accountable under Indian law.

APR is a mandatory filing with the RBI, as FEMA states that the authorized person (and, if it’s a company, its directors, partners, or officers) must cooperate with RBI rules and regulations; otherwise, they may face penalties.

The authorized person here refers to individuals or entities that the RBI permits to deal in foreign exchange or foreign securities.

Don’t delay your APR filing; get professional assistance today and file it as soon as the deadline arrives.

Conclusion

Filing an Annual Performance Report (APR) is a mandatory compliance requirement for every Indian resident or entity holding ODI. It ensures transparency and helps the Reserve Bank of India (RBI) monitor foreign investments made by Indian residents. Missing or incorrectly filing the APR can lead to compliance issues and penalties under FEMA regulations.

At Mercurius, our team of experienced professionals assists businesses and individuals in preparing, reviewing, and filing APRs accurately and on time. We ensure complete compliance with RBI and FEMA guidelines, handle documentation, coordinate with foreign accountants, and simplify the entire process for you — so you can stay focused on your business while we take care of the regulatory side. For further details, you can contact us!