Ask five finance teams what they file every December for their overseas subsidiary, and you will hear “the APR”, “ODI Part II”, “the ODI form” and “Form APR”. All of them are referring to the same document. Whether your bank writes one name or the other on its checklist changes nothing about what you must submit, but it can change which template you are handed.
The short answer is one report, two labels. The Annual Performance Report is the yearly return an Indian investor files for each foreign entity it holds under ODI. Since the overseas investment framework took effect on 22 August 2022, RBI’s prescribed format is titled “Annual Performance Report (APR)”. Before that, the same report was filed in a form called ODI Part II. So “Form APR” is the current name, and “ODI Part II” is the older name that never quite went away.
How the confusion started. The 2022 framework replaced the old FEMA Notification 120 regime, but old habits outlast legal changes. The label “ODI Part II” survives in RBI’s own late-fee table, which still reads “Form ODI Part-II/APR” for the flat Rs 7,500 fee, in bank checklists written before 2022, and in practitioner guides that use both names.
What the current Form APR contains. More useful than the name is what the document holds: the period covered and the UIN, the capital structure of the foreign entity, changes in shareholding during the year, two years of financial position, repatriation and retained earnings, details of any step-down subsidiary, a declaration by the Indian investor, a signed block by the statutory auditor or a chartered accountant with a UDIN, and an AD bank block.
Which name does your AD bank use? No public source can tell you for a specific bank, since a branch may use whatever wording its ODI desk has always used. Ask for the bank’s ODI checklist and the template it wants uploaded. If the checklist says “ODI Part II” but the template has the fields above, the bank is simply using the old name for the current form. If the template lacks the step-down subsidiary section, the declarations or the auditor and bank blocks, you may have an older layout, so ask the bank to confirm it is the format RBI prescribed in 2022.
Why the wrong template can cost you. Failing to report step-down subsidiary or shareholding changes amounts to non-submission of the APR, and an old template will never remind you. It may also leave out declarations such as confirming that share certificates reached the AD bank within six months. And if the bank finds the problem late, you will be redoing it against the December deadline, alongside the audit sign-off.
Keep the naming consistent. In engagement letters, a safe wording is “for the Annual Performance Report under the Overseas Investment Regulations, 2022”, which is accurate under either name. In your own records, use one label, for example “APR (Form APR, earlier Form ODI Part II)”.
Read the complete guide, including a quick checklist for this December:
https://accorppartners.com/blogs/apr/form-apr-vs-form-odi-part-ii-which-name-does-your-ad-bank-use-in-2026
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