Compliance calendar
RBIRBI and FEMAForm DI

Form DI (downstream investment)

The SMF report for downstream investment that is treated as indirect foreign investment.

How this is timed

Downstream allotment

Counted from allotment of equity instruments by the downstream investee

Regulator
RBI
Category
RBI and FEMA
Form
Form DI
Last verified
2026-09-01

Form DI is due within 30 days from the allotment of equity instruments by the downstream investee. A second 30-day clock applies when a resident-owned or controlled investor entity becomes foreign owned or controlled. File through the Single Master Form on FIRMS.

What changed

RBI released draft FEMA (Foreign Investment) Rules, 2026 on 21 July 2026. They were not notified by 1 September 2026, so the NDI Rules 2019 position still applies. Re-check this row when the final rules are notified because its legal basis may be re-based.

Deadlines counted from an event

These have no calendar date. The clock starts when the event happens.

Downstream allotmentfrom allotment of equity instruments by the downstream investee

File Form DI within 30 days from the allotment of equity instruments.

Applies when: The entity or investment vehicle makes downstream investment.

Investor becomes foreign owned or controlledfrom the resident investor entity becoming foreign owned or controlled

File Form DI within 30 days from the reclassification.

Applies when: A resident investor entity that already made downstream investment later becomes foreign owned or controlled.

The rule

Stated as the law states it, so you can work out any period yourself.

Downstream allotment

File Form DI within 30 days from the allotment of equity instruments.

Applies when: The entity or investment vehicle makes downstream investment.

Investor becomes foreign owned or controlled

File Form DI within 30 days from the reclassification.

Applies when: A resident investor entity that already made downstream investment later becomes foreign owned or controlled.

Who must comply

  • An Indian entity or investment vehicle that makes downstream investment treated as indirect foreign investment
  • A resident investor entity that becomes foreign owned or controlled after making downstream investment

Statutory basis

Read the provision here where we hold it, or on the regulator's site.

Before you file

  • Confirm that the downstream investment is treated as indirect foreign investment.
  • Identify whether allotment or reclassification starts the 30-day period.
  • Keep the entity master current on FIRMS.

How to file

  1. 1Open the Single Master Form on FIRMS.
  2. 2Select Form DI.
  3. 3Enter the downstream investment details.
  4. 4Submit the form within 30 days from the applicable trigger.

FIRMS Single Master Form portal

Last verified 2026-09-01. Confirm against the official source before you rely on it.