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FORM-CNmediumReserve Bank of India

Convertible Notes Issued to a Non-Resident: due date and penalty

Also searched as: FORM-CN

A recognised start-up reports the issue of convertible notes to a person resident outside India within 30 days of issue, and reports the transfer of such notes on the same form.

When it is due

30 days from the date of issue of the notes

If it is late: Late Submission Fee on the amount involved and the period of delay

Track Convertible Notes Issued to a Non-Resident and every other filing — free for 14 days
Due
30 days from the date of issue of the notes
Frequency
Event based
If it lapses
Late Submission Fee on the amount involved and the period of delay
Statutory reference
Reg. 4(12), FEM (Mode of Payment and Reporting of Non-Debt Instruments) Regulations 2019 (FEMA 395/2019-RB)

Where this date comes from

The instrument
Reg. 4(12), FEM (Mode of Payment and Reporting of Non-Debt Instruments) Regulations 2019 (FEMA 395/2019-RB)

Mallah Software Services Private Limited has not independently verified this against the gazette. The citation above is the instrument this date is taken from, and it is exact enough for a professional to check. Inside Lawzer a company secretary or chartered accountant can record that they have checked it, against the rule as it read on the day — and that record is withdrawn automatically if the rule later changes. A date nobody has checked says so.

Who has to file it

Every one of these has to hold before Convertible Notes Issued to a Non-Resident binds an entity:

  • foreign investment on record
Filed on:
RBI FIRMS Portal
Usually owned by:
Company Secretary
Typical effort:
3 hours

Common questions

What is the due date of Convertible Notes Issued to a Non-Resident?
30 days from the date of issue of the notes. It falls due whenever the triggering event happens.
Who has to file Convertible Notes Issued to a Non-Resident?
It applies to foreign investment on record.
What is the penalty for filing Convertible Notes Issued to a Non-Resident late?
Late Submission Fee on the amount involved and the period of delay
Where is Convertible Notes Issued to a Non-Resident filed?
RBI FIRMS Portal.

This is the standing statutory position. The government extends deadlines often, and an extension is not reflected here until the rule is updated. Mallah Software Services Private Limited is a software company and not a firm of company secretaries or chartered accountants — nothing here is legal, tax or secretarial advice. Confirm the date with your professional before relying on it. See the Professional Disclaimer.

Other FEMA / RBI obligations