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ENTITY - User Manual

The document is a user manual for the Foreign Investment Reporting and Management System (FIRMS) provided by the Reserve Bank of India, detailing the process for entity users to report foreign investment in India. It outlines the registration process, user responsibilities, and the structure of the Single Master Form (SMF) for reporting various types of foreign investments. Additionally, it includes information on the Entity Master, necessary documentation, and guidelines for maintaining user profiles within the FIRMS application.
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0% found this document useful (0 votes)
1K views33 pages

ENTITY - User Manual

The document is a user manual for the Foreign Investment Reporting and Management System (FIRMS) provided by the Reserve Bank of India, detailing the process for entity users to report foreign investment in India. It outlines the registration process, user responsibilities, and the structure of the Single Master Form (SMF) for reporting various types of foreign investments. Additionally, it includes information on the Entity Master, necessary documentation, and guidelines for maintaining user profiles within the FIRMS application.
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

RESERVE BANK OF INDIA

FOREIGN EXCHANGE DEPARTMENT

FOREIGN INVESTMENT REPORTING AND MANAGEMENT SYSTEM


(FIRMS)

USER MANUAL FOR ENTITY USERS


Version No. Date of Change Changes Made Pages
1.0 10-05-2024 Introduction 4
Annexure – II: List of Regional Offices 30 and 31
of RBI
2.0 26-06-2024 Changes indicated with $ NA
3.0 19.12.2024 Changes indicated with ^ NA

2|Page
Table of Contents:

Foreign investment in India - Reporting in Single Master Form ......................4


USER MANUAL FOR ENTITY MASTER ............................................................5
1. Who is an Entity?.........................................................................................5
2. Process Flows – ...........................................................................................5
3. Process flow for Entity Master – .............................................................5
4. Registration for an Entity User – .............................................................6
5 Entity Master – ............................................................................................15
6 Important Notes for Entity Master: .......................................................27
7 Contact Us: ..................................................................................................27
8 Do’s and Don’t’s: .......................................................................................28
ANNEXURE – I – Letter of Authorization ..........................................................30
ANNEXURE – II: List of Regional Offices of RBI .............................................32
ANNEXURE – III: Format for modification requests in Entity Master ...........33

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FIRMS APPLICATION

Foreign investment in India - Reporting in Single Master Form

Introduction:
1.1 The Reserve Bank, in the First Bi-monthly Monetary Policy Review dated April 05,
2018 announced that, with the objective of integrating the extant reporting structures of
various types of foreign investment in India, it will introduce a Single Master Form (SMF)
subsuming all the existing reports.

1.2 In order to implement this announcement, the Reserve Bank introduced an online
application, FIRMS (Foreign Investment Reporting and Management System), for
enabling reporting in SMF. FIRMS was made live in two phases. In the first phase, the
first module viz., the Entity Master, was made available online. Instructions in this regard
were already issued through A.P. (DIR Series) Circular No. 30 dated June 07, 2018
(https://rbi.org.in/Scripts/BS_CircularIndexDisplay.aspx?Id=11297).

1.3 In the second phase, the second module containing 9 reports was made available
with effect from September 01, 2018. With the implementation of SMF, the reporting of
FDI, which was a two-step procedure viz., ARF and FC-GPR was merged into a single
revised FC-GPR. The SMF also introduced reporting of indirect foreign investment
through form DI and reporting of inflows in investment vehicles through Form InVi.
Further, the reporting in FC-TRS, LLP-I, LLP-II, ESOP, DRR and CN was also made
available in SMF. The finalized structure of SMF and operational instructions thereof were
made available in the Master Direction on Reporting under FEMA, 1999.

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USER MANUAL FOR ENTITY MASTER

1. Who is an Entity?
 A company within the meaning of section 1(4) of the Companies Act, 2013.
 A Limited Liability Partnership (LLP) registered under the Limited Liability Partnership
Act, 2008.
 $A startup as defined under the Foreign Exchange Management (Non-Debt
Instrument) Rules, 2019.

2. Process Flows –
2.1 Schematic representation of Entity User Registration and Entity Master:

3. Process flow for Entity Master –


3.1 Entity User:
 An Entity User is a person authorized by the Entity (company/ LLP/startup) to register
an Entity in the Entity Master of FIRMS application.
 The Entity User would be the sole person authorized to add/ update the foreign
investment details of an Entity in the Entity Master and would be entirely responsible
for the data entered.

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 One Entity can have only one Entity User. If the Entity wishes to change the Entity
User, it may contact the FIRMS helpdesk, the details of which are available in the
“Contact Us” section.
 One person can also be an Entity User for more than one Entity. However, the person
has to obtain separate registrations for the same as the registrations are Entity
specific.

4. Registration for an Entity User –

4.1 Pre-requisites:

 Authority Letter: The Entity may issue an Authority Letter, in the format as given at
Annex to the identified personnel authorizing him/her for registering as an Entity User
for the Entity.
 The Entity User may keep ready all details of foreign investment in the Entity.

4.2 Registration Process:

 Uniform Resource Locators (URL) of the application is https://firms.rbi.org.in.


 The person, for registering as Entity User, may access the login page of the FIRMS
application using the above URL on the internet.

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4.3 Landing page for Registering an Entity User:

4.4 Creation of new Entity User:


Step 1: Click on Registration form for New Entity User.
Step 2: A pop-up box showing Entity User Registration form opens.

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$Note: The entities registered as LLPs have to necessarily click on the radio button for
“Limited Liability Partnership” in the above screen for prescribed filing.

Step 3: Fill all the details in the Entity User Registration Form.

4.5 Field Descriptions:


The fields in the Entity User Registration Form are described in the following table –
Field Name Field Description
First Name* First Name of the User
Middle Name Middle Name of the User
Last Name* Last Name of the User
User Name* User has to enter a unique Username. The Username
can be alphanumeric.
Email* The User has to enter a valid e-mail ID. The default
Confirm Email* password will be provided in the e-mail ID.

PAN Number* The User should provide their own PAN No. (not the
PAN No. of the company).
It is composed of 10 characters (first five alphabets,
next four numerics, and the last alphabet).
Mobile Number* The User should enter its valid 10-digit mobile number.
Entity Name* Name of the company as per the certificate of
incorporation
(Only name of the company without any prefixes).
Company Type* Entity type whether Company, LLP, or Start Up.
CIN or LLPIN* If Company is selected, then CIN of the Entity as
available in the certificate of incorporation has to be
entered. If the company does not have CIN number, it
may fill a dummy CIN number as below –

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D12345(first two letters of the state where company has
registered office)2010(first three letters of the company’s
name) (123456)
For example: If the Company’s name is ABC Corporation
Limited and the Registered Office is in Maharashtra,
where the company does not have a CIN, then dummy
CIN would be –
D12345MA2010ABC123456

Similarly, if LLP is selected, then LLPIN of the Entity as


available in the certificate of incorporation has to be
entered. If the LLP does not have an LLPIN, it may enter
a dummy LLPIN as below –

D(first two letters of the LLP’s name)(date and month of


incorporation in digits)

For example: if the LLP’s name is ABC LLP and date of


incorporation is October 23,1990, then the dummy LLPIN
would be-
DAB-2310
Regional Office Regional Office of RBI under whose jurisdiction the
Name* registered office of the Entity falls. Entities are advised to
refer to Annexure-II for confirmation.
Address* City with the PIN Code of the registered office of the
Entity.
Authority Letter* The User has to attach the authority letter $(Max size:
1Mb) from the Entity authorizing the person to register as
an Entity User for submission of information in the Entity

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Master. The format of the authorization letter is provided
in Annexure-I.
Only a ‘.pdf’ file can be attached.
*Denotes Mandatory fields.

Step 4: Click on the Submit button after filling in all the details.
Step 5: A notification “Record saved successfully” would pop up. This means that the
User has created its User ID.

Authority Letter submitted by the Entity User will be verified by the RBI and after the RBI’s
approval, the User would receive the password on his/ her registered email ID from RBI’s
mail ID ([email protected]).

(i) $(Note: Users not receiving any mail notification for approval/ rejection of the
registration within 48 hours may contact the respective Regional Office of the
Reserve Bank – (Please refer to Contact Details document in the FIRMS
homepage).

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A Sample mail is given below:

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First time Logging in:

Step1: Enter the Username and Password as provided to the User in the email from RBI
and click Login. The User would be asked to change his/her password upon first Login.

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4.6 Change Password:
Step 1: The Change Password window is displayed.

Step 2: Enter your old password in the “Old Password” field and the new password in the
“New Password” field.

Step 3: Re-enter the new password to confirm it and click “Continue”.

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4.7 $Change in Email id/ Contact Number:
In case the Entity User wants to edit his/ her already existing e-mail id & contact
number, the following steps shall be followed.
Step 1: After logging into the FIRMS portal, the Entity User should click on the main
menu (hamburger) on the left and then select User >> User Profile.
Step 2: Once selected, the existing profile details of the Entity User will be displayed.
The Entity User has to then click on the ‘Edit’ button to open the Edit User Profile tab.
Please refer to the image below –

Step 3: The Entity User will be able to edit only his/ her existing Email id & Contact
number. Once these changes are made, the User has to click on ‘Save’ button to
record these changes in the system.
Step 4: The screen will display a ribbon on top indicating that the User details have
been updated successfully. Further, an automated confirmation e-mail will also be
triggered to the Entity User’s E-mail id by FIRMS.

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5 Entity Master –
5.1 Logging on to Entity Master: Enter your Username and new Password.
5.2 Entry in Entity Master: On successful login the home page (dashboard) is displayed.

Step 1: Click on the top - left option button to open Menu.


Step 2: Click on the ‘Master Setup’ button under Menu. Then click on the ‘Entity
Master’ button. The following page is displayed –

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5.3 Entity Details:
Step 3: Click on the “Add” button. The Entity details page would be displayed -

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Step 4: Click on the ‘Entity Details’ tab:

The fields in the Entity Details are described in the following table –
Field Name Requirement
Name of the Entity Will be auto-populated as per the
details in the Registration Form.
CIN/ LLPIN Will be auto-populated as per the
details in the Registration Form.
Date of incorporation* As appearing in the Certificate of
Incorporation (Cannot be a future date).
Permanent Account Number (PAN)* PAN No. of the Entity.
RBI Registration Number The number provided by RBI during
reporting of earlier allotments, if any,
has to be entered.
Whether the company/LLP is under As the case may be for the Entity.
investigation by Directorate of
Enforcement/CBI or any other investigative
agency for violation of FEMA, 1999*
*Denotes Mandatory fields

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Step 5: Click on the ‘Particulars’ tab:

The following page would be displayed.

Please add the pin code nearest to your area in case the pin code specific to your area
is not displayed.

The fields in the Particulars tab are described in the following table –
Field Name Requirement
Address of the registered As appearing in the certificate of incorporation
office* / in case of change of address as appearing in Form
INC 22.
Pincode* Choose from the Dropdown
Mobile Number* Mobile Number of the Authorised Person, example –
Director, Company Secretary for the Company, etc.
Telephone Telephone Number of the Company (prefix with STD
Code), example – 022-12345678
$Company Email* Email Id of the Entity/ Company
NIC Code* If more than one applicable, then main activity for
which the foreign investment is received.
Greenfield or Brownfield Select whether ‘Greenfield’ or ‘Brownfield’.
*Denotes Mandatory fields

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Step 6: Click on the ‘Foreign Investment in Company/ LLP’ tab:

Following page would be displayed-

(a) If Company:

Paid-up Capital of the company on a fully diluted basis (where paid-up capital is on
a fully diluted basis) = Paid up shares on fully diluted basis * face value (in INR)

Where, ‘Fully diluted basis’ means the total number of shares that would be outstanding
if all possible sources of conversion are exercised. It includes:

(i) Equity Shares: As equity shares.


(ii) CCDS/ CCPS: Equivalent Equity shares (if the conversion ratio is not fixed upfront),
the company may enter the maximum number of equity shares possible upon
conversion in compliance with the pricing guidelines.
(iii) Share warrants: Equivalent Equity shares considering 100% exercise upfront.
(iv) ESOPs: Equivalent Equity shares considering 100% exercise upfront.

Note: If a start-up company has issued convertible notes, the same shall not be
included in the paid-up capital on fully diluted.

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To report only Capital Instruments held by persons resident outside India on a
repatriable basis.

(v) The Indian companies who have made downstream investment in another
Indian company for which it is considered as indirect foreign investment in terms of
Regulation 14 of Foreign Exchange Management (Transfer or issue of security
by a person resident outside India) Regulations, 2017 dated November 7, 2017
and as amended from time to time, shall inform the same to the Indian investee
company for the purpose of providing details of indirect foreign investment in Entity
Master.

(b) If LLP: Total Capital contribution in the LLP (in INR).


(c) Foreign Investment:
 The Entity should also report indirect foreign investment received by it $(if
applicable).
 The Entity shall provide the details of all foreign investment as on date on an
aggregate level as below. This will also be inclusive of all foreign
investment, irrespective of the fact that the regulatory reporting to
RBI for the same has been made or not or whether the same has
been acknowledged or not.

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The fields in the Foreign Investment in a Company/ LLP are described in the following
table:

Field Name For Company/ Start-up For LLP/ Start-up


Paid-up capital/ Capital Total paid up capital of the company Total Capital
Contribution* $(domestic plus foreign investments contribution in LLP
including indirect foreign investment) (in INR)
on a fully diluted basis in INR
Foreign Portfolio Foreign Portfolio Investments Will be disabled
Investment* made (value of shares, where
(Investment that is Value of Shares = No. of
considered as foreign shares * Face Value) by Foreign
portfolio investment Portfolio Investors (FPI)/ Non-resident
$within the meanings Indian (NRI).
defined under FEMA 20/ Others will include foreign portfolio
FEMA 20(R)/ NDI Rules, investments made in
2019 the company other than by
FPI/ NRI.
$Will be disabled (Unlisted Entities)
Foreign Investment in Value of equity shares issued by the Capital
Company/ LLP company on a fully diluted basis other contributions/ Profit
than Foreign Portfolio Investment and shares (in INR)
indirect foreign investment, where
value of shares = No. of shares * Face
Value
Value of Equity Shares/ Foreign Portfolio Investment and
Capital Contributions indirect foreign investment, where
(Investment that is value of shares = No. of shares * Face
considered as foreign Value
direct investment $within
the meanings defined

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under FEMA 20/ FEMA
20(R)/ NDI Rules, 2019
Indirect Foreign Indirect Foreign Investment in the Indirect Foreign
Investment Company (in value of shares) Investment in LLP
(in INR)
*Denotes Mandatory fields

Prior to July 20, 2018, the Tab-3 of Entity Master was as below –

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Field Name For Company/ Start-up For LLP/ Start-up
Paid-up Capital/ Capital On a fully diluted basis in Total Capital Contribution
Contribution INR in LLP (in INR)
Face value of the shares* Face value of the shares Will be disabled
issued
Foreign Portfolio Foreign Portfolio Will be disabled
Investment* Investments made by
Foreign Portfolio Investors
(FPI)/ Non-resident Indian
(NRI).
Others will include foreign
portfolio investments made
in the company other than
FPI/ NRI.
Foreign Investment in Number of equity shares Capital Contributions/ Profit
Company/ LLP: issued by the company on shares (in INR)
a fully diluted basis other
Number of Equity Shares/ than Foreign Portfolio
Capital Contributions Investment and indirect
foreign investment
Indirect Foreign Investment Indirect Foreign Investment Indirect Foreign Investment
in the Company (in in LLP (in INR)
numbers)

Note: The companies which have already filled in the data in the Entity Master, prior to
July 20, 2018, may please check that the values in data fields as being reflected are
correct with respect to the value of shares and percentage holding.

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Step 7: Click on the ‘Foreign Investment Info’ tab. The following page would be
displayed –

Enter all the foreign investment received by the Entity since the date of incorporation.

[Note: Details of each issue/ transfer (and not investor wise) have to be filled in this page,
one after the other, i.e., after entering the details of one issue, the User should click on
the ‘Add’ button (top-right corner of the screen) and add the details of the next issue/
transfer.]

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The fields in the ‘Foreign Investment Info’ tab are described in the following table –

Field Name Requirement


Date of Issue/ Transfer Enter the date of allotment/ transfer in dd/mm/yyyy format.
Description Description of the allotment/ transfer (whether Rights/ Bonus/
Share Swap/ Merger/ Demerger/ ESOP/ NR to R transfer/ R
to NR transfer, etc.)
Instrument Type/ In the case of Company: Equity Shares, CCPS, CCDs, Share
Capital Contribution/ or Warrants, Partly paid up shares.
profit share for an LLP In the case of LLP: Capital Contribution of Profit Share.
In case of Start-ups: Convertible notes.
Number of Instruments/ In case of Company, number of capital instruments issued to
Percentage of Capital the foreign investors to be provided.
Contribution In case of LLP, percentage of capital contribution received
from the foreign Entity to be provided.

$(Note: A company that has created its Entity Master and has already allotted shares
which were not reported in the Entity Master, but were reported earlier in e-biz, may
update the same in the Entity Master at ‘Foreign Investment in Company/ LLP’ and
‘Foreign Investment Info’).

5.4 Declaration:

Step 8: After all the issues / transfers have been added, User will have to click the
declaration check box to enable submission of the Entity master.

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5.5 Submission:

Step 9: Only after the declaration is checked, the Entity User can submit the details.

Once the details of the Company have been submitted, it will be available on the Entity
Master Page. No email acknowledgement would be sent for the submission in the
Entity Master.

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6 Important Notes for Entity Master:
(ii) All the details must be provided in one go.
(iii) Only when all the mandatory fields have been filled, the submit button is enabled.
(iv) The RESET button will reset the complete form.
(v) $Requests for modification in entity master details have to be submitted (over mail/
physically) to the respective Regional Office of the Reserve Bank (Please refer to
Contact Details document in the FIRMS homepage), ^along with a declaration as
specified in Annex III.
(vi) The onus of the integrity of the data entered is on the Entity User.

7 Contact Us:
Helpdesk for FIRMS to receive queries from stakeholders regarding entries to be made
in FIRMS or to raise any issues encountered while creating/ updating the Entity Master.
^For changes in the Entity Master/ queries related to changes in the Entity
Master, applicants are advised to contact the respective Regional Office of RBI,
under whose jurisdiction the registered office of the entity is situated. Contact
details/ E-mail id of RBI’s Regional Offices are available on the home page of
FIRMS portal. No such requests should directly be sent to the FIRMS Helpdesk.

In case of any further help, applicants may call/ write to the Helpdesk for FIRMS.

FIRMS Helpdesk
E-mail: [email protected]
Telephone Number: 022 - 22601000 (Extension: 2617)

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8 Do’s and Don’t’s:

Sr. No. Do’s


1. In case of rejection of registration, use another User Name for fresh
registration (other than the one given earlier).
2. While logging in, manually type the User ID and Password (do not copy
& paste).
3. In case of account gets locked/ blocked, send an e-mail to
[email protected]
4. The Authorisation letter should be in the prescribed format as given in the
User Manual available on the RBI website.
5. The nominated person and the authorizing person should be different.
6. The Authorisation letter should be dated on or after June 28, 2018.
7. PAN of the Entity User should be filled in the registration form.
8. A copy of the PAN Card of the Entity User should be attached.
9. The CIN given in the Registration Form and Authorisation letter should be
same.
10. The name of the authorised person in the Registration form and the
Authorisation letter should be the same.
11. CIN/ LLPIN given in the registration form and Authorisation letter should
be the same.
12. The Authorisation letter should be on the Entity’s letterhead.
13. The authority letter should be signed by the proper Authority as given in
the prescribed format.
14. The Seal/ Stamp of the Company/ LLP should be affixed.
15. Valid data should be entered.
16. The attached 'pdf' should be readable.
17. Valid e-mail ID should be filled in the Registration Form to ensure receipt
of User ID and default Password.
18. Entity User should provide Specimen signature in the Authorisation letter.

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Sr. No. Don’t’s
1. While logging in, do not Copy and Paste the User ID and Password. The
same should be typed out.
2. The Authorization letter cannot be signed by the person nominated by the
company. It should be signed by another person from the company as
given in the prescribed format.
3. PAN of the Entity should not be filled in the Entity Registration Form.
4. Copy of PAN Card of Entity should not be attached.
5. Invalid data should not be entered.

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ANNEXURE – I – Letter of Authorization
(ON THE ENTITY’s LETTER HEAD)

The Chief General Manager-in-Charge Date: dd/mm/yyyy


Foreign Exchange Department
Reserve Bank of India
# Regional Office
^^____________.

Dear Sir,
Sub: Letter of Authorization for creation of Entity User in FIRMS

We hereby authorize Shri. / Smt. / Ms. _______________ (Name and Designation)


holding Permanent Account Number (PAN) ____________________ (copy to be
attached) to register as the Entity User for submission of information in the Entity Master
of the Foreign Investment Reporting and Management System (FIRMS) on behalf of our
company/ LLP named ___________________________, having registered office at
______________________ and PAN _____________.
#The CIN/ LLPIN is __________/ Company/ LLP is not required to obtain CIN/ LLPIN.

2. We also authorize Shri. / Smt. / Ms. __________________ (Name of Authorized


Representative) to make declarations and to submit documents, wherever
required, on our behalf. These declarations and submissions are made towards the
requirement of the Foreign Exchange Management Act, 1999 and any other applicable
laws that may be in force.

3. We further confirm that we are liable for and bound by all acts of commission and
omission by the authorized representative. All acts committed by the above authorized
representatives shall be treated as if these acts were committed by the company/ LLP.

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The Specimen signature of Shri. / Smt. / Ms. __________ (Authorized representative) is
attested below:

____________________________________
(Specimen Signature of authorized representative)

Yours faithfully,

____________________________________
Signature of Managing Director/ Director/ Secretary
of the Company/ Designated Partner (in case of LLP)

Name :
Designation :
Date :
DIN/ Registration Number of Secretary/ DPIN of Partners:
Seal of the signing authority:

# Strike out whichever is not applicable


^^ Indicate the location of RBI Regional Office

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ANNEXURE – II: ^List of Regional Offices of RBI

All the Entity Users are advised that for selecting the Regional Office of RBI while
submitting Entity User application form, the following table may be referred to –
Sl. No Name of RO Jurisdiction
State of Gujarat, Union Territories of Dadra and Nagar Haveli and
1 Ahmedabad
Daman and Diu
2 Bengaluru State of Karnataka
3 Bhopal State of Madhya Pradesh & State of Chattisgarh
4 Bhubaneswar State of Odisha
State of Himachal Pradesh, State of Punjab, Union Territory of
5 Chandigarh Chandigarh and State of Haryana (excluding the Districts of
Faridabad, Gurgaon and Sonepat of the State of Haryana).
6 Chennai State of Tamil Nadu and Union Territory of Puducherry
States of Arunachal Pradesh, Assam, Manipur, Meghalaya, Mizoram,
7 Guwahati
Nagaland and Tripura.
Hyderabad State of Andhra Pradesh
8
(Andhra Pradesh)
Hyderabad State of Telangana
9
(Telangana)
10 Jaipur State of Rajasthan
11 Jammu Union territory of Jammu and Kashmir, and Union territory of Ladakh
State of Uttarakhand and State of Uttar Pradesh (excluding
12 Kanpur SubDivision of Noida in Gautam Buddha Nagar District of State of
Uttar Pradesh)
13 Kochi State of Kerala, and Union Territory of Lakshadweep
State of Sikkim, State of West Bengal, and Union Territory of
14 Kolkata
Andaman and Nicobar Islands
15 Mumbai State of Maharashtra
Union Territory of Delhi, the Districts of Faridabad, Gurgaon, and
16 New Delhi Sonepat of State of Haryana, SubDivision of Noida in Gautam Buddha
Nagar District of the State of Uttar Pradesh
17 Panaji State of Goa
18 Patna State of Bihar and State of Jharkhand

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ANNEXURE – III: ^Format for modification requests in entity master

(On Letter head of the company)

Request for Entity Master Modification

• User ID:
• CIN/LLP Number:
• Registered Email Id:
• Issue description (Reasons for the change):
• Changes need to be done:
Sr. Data field to Old value
New Value (to be updated)
No. be updated (existing)

We/I hereby declare that,

1. We/ I have verified the information provided in this request letter and certify that
the information provided is true, complete and correct. In case of any discrepancy
in the above information, We/I may be held liable for the same. These declarations
and submissions are made in compliance to the Foreign Exchange Management
Act, 1999.

2. We/I comply with the procedure for receiving foreign inflow as laid down under
FEMA or the rules and regulations framed, or directions issued thereunder as
amended from time to time and as applicable.

Signature of the Applicant : __________________________________________


(Name in Block Letters) : __________________________________________
(Designation of the signatory) : __________________________________________
Place:
Date: _ _/ _ _/ _ _ _ _
Company seal

(Please attach a scan copy of request letter signed by Managing Director / Director
/ Secretary of the Company / Designated Partner (in case of LLP)

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Common questions

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An LLP must report all indirect foreign investments it has received. These investments should be reported in aggregate, covering all foreign investments up till date, whether compliance with regulatory reporting to the RBI has been completed or not. The Entity should also provide details on indirect foreign investments, highlighted under the 'Foreign Investment in Company/ LLP’ tab within the FIRMS application .

Registering an Entity User for an LLP under FIRMS involves several steps. First, the person authorized by the LLP completes an authority letter to register as an Entity User. The person then accesses the FIRMS application via its URL and fills out the Registration Form for a New Entity User. This includes selecting 'Limited Liability Partnership' on the form, completing mandatory fields such as PAN, email, and mobile number, and attaching the authority letter as a PDF. After submission, the RBI verifies the authority letter and, upon approval, sends the default password to the registered email. The user changes this upon first login .

A startup should include comprehensive details about all foreign investments received since its incorporation. For each issue or transfer, the startup must separately fill in specifics like the date of issue/transfer, instrument type, and number or percentage of capital contributions. Transfers not reported earlier in e-biz must also be updated in the Entity Master to ensure compliance .

Yes, an individual can serve as an Entity User for multiple entities within the FIRMS application. However, they must obtain separate registrations for each entity, as registrations are specific to each entity. This ensures that foreign investment details are appropriately managed and reported for each separate legal entity .

If an LLP identifies discrepancies in the Entity Master details, it should submit requests for modification to the respective Regional Office of the Reserve Bank. These requests must be accompanied by a declaration as specified by RBI guidelines. Direct contact with FIRMS Helpdesk is not recommended for these changes, emphasizing formal regional office channels instead .

If a user does not receive mail notification for approval or rejection within 48 hours after registration, they should contact the respective Regional Office of the Reserve Bank. The contact details can be found in the FIRMS homepage help section, and following up ensures any potential errors or delays in registration are promptly addressed .

LLPs that entered data into the Entity Master prior to July 20, 2018, must ensure that the values for data fields such as total capital contributions are correct, reflecting accurate values and percentage holdings. Any needed corrections or updates should be validated against current data requirements to maintain compliance .

Should an Entity User face account lock or access issues in the FIRMS application, the person should send an email to [email protected] for resolution. It is important not to attempt repeated logins as it could complicate the issue. Assistance can also be sought via the telephone number provided by the FIRMS Helpdesk .

An LLP may issue a dummy LLPIN if it does not have one available. The dummy LLPIN format includes the first two letters of the LLP’s name, followed by the date and month of incorporation in digits. This is a temporary measure meant to facilitate the registration process when the necessary identification numbers are unavailable .

The Entity User holds full responsibility for the integrity and accuracy of the data entered in the FIRMS application. It is critical that the Entity User ensures all entries are correct as they are the sole individual authorized to make these updates. Inaccuracies could lead to compliance issues, and thus the Entity User needs to diligently verify all information before submission .

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