What changed
Earlier, AACs for BOs/LOs had to be filed by April 30 every year. Now, the deadline is pushed to September 30 for accounts ending March 31. For non-March year-ends, AACs must be submitted within six months from the balance sheet due date.
What it means for you
Banks get more time to collect and verify AACs from foreign BOs/LOs, reducing rush and errors. This also gives foreign entities extra months to finalize audits. However, all other compliance requirements from the December 2009 circular remain unchanged.
What you must do
- Update internal compliance calendars for BO/LO AAC submissions to September 30 deadline.
- Notify all foreign BO/LO clients about the revised timeline and documentation requirements.
- Ensure that for non-March year-end accounts, AACs are collected within six months of balance sheet due date.
- Maintain records of AACs and audited balance sheets as per existing FEMA guidelines.
Who it affects
Category-I Authorised Dealer banks, Foreign Branch Offices in India, Foreign Liaison Offices in India, Auditors of foreign BOs/LOs
What is the new deadline for submitting AACs for BOs/LOs with March 31 year-end?
The AAC along with audited balance sheet must be submitted on or before September 30 of that year, instead of the earlier April 30 deadline.
What if the BO/LO's financial year ends on a date other than March 31?
In such cases, the AAC and audited balance sheet must be submitted within six months from the due date of the balance sheet.
Does this circular change any other compliance requirements for BOs/LOs?
No. All other instructions from A.P. (DIR Series) Circular No.24 dated December 30, 2009 remain unchanged.