Compliance calendar
RBIRBI and FEMAForm ESOP

Form ESOP (options issued to non-resident employees)

The SMF report for employee stock options that an Indian company issues to persons resident outside India.

How this is timed

Issue of employee stock options

Counted from issue of employee stock options to a person resident outside India

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

Form ESOP is due within 30 days from the issue of options to a person resident outside India. It reports the option issue. If the employee later exercises the option and receives shares, report the share issue separately in FC-GPR.

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.

Issue of employee stock optionsfrom issue of employee stock options to a person resident outside India

File Form ESOP within 30 days from the date of issue of the options.

The rule

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

Issue of employee stock options

File Form ESOP within 30 days from the date of issue of the options.

Who must comply

  • An Indian company that issues employee stock options to a person resident outside India

Statutory basis

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

Before you file

  • Complete the issue of the employee stock options.
  • Keep the entity master current on FIRMS.

How to file

  1. 1Open the Single Master Form on FIRMS.
  2. 2Select Form ESOP.
  3. 3Enter the option issue details.
  4. 4Submit the form within 30 days from the issue date.
  5. 5File FC-GPR separately when shares are issued on exercise.

FIRMS Single Master Form portal

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