Every year the same pattern repeats. Companies with overseas subsidiaries treat 31 December as a single date, when it is really the finish line of a three-month process. The APR form and the AD Bank submission take very little time once everything is ready. What eats the calendar is the audit of the foreign subsidiary’s financials, which usually runs 60 to 90 days once a qualified auditor is engaged.
Here is how to split the work across the three months.
October is when the clock starts. Confirm your ODI structure, including your UIN, last year’s APR history and any change in shareholding or step-down subsidiaries. Engage the right auditor for the jurisdiction: a licensed US CPA for a US entity, and an ICAEW or ACCA-qualified professional for a UK entity. A report signed by the wrong type of professional is rejected by the AD Bank. Start collecting the subsidiary’s balance sheet and profit and loss statement, and deal with any prior-year defaults now.
November is where most delays happen. The audit should be underway, not just started. Answer auditor queries within days, not weeks. Reconcile draft figures against your original ODI records, covering the amount invested, shareholding, loans and guarantees. If you have subsidiaries in more than one country, track every audit against the same finish line. Book the Indian CA review now, so you are not hunting for availability in December.
December is execution, not preparation. Assemble the full dossier before submitting: audited financials, the signed auditor certification, a UIN that matches across every document, and a correctly filled Form ODI Part II. Submit in the first half of the month so there is room to handle a bank rejection, and keep following up until you hold a stamped acknowledgement, not just a submission confirmation.
If it is already December and the audit has not started, the timeline is tight but not lost. Every step needs to move with urgency, and having one team coordinate the audit, CA review and submission helps.
Read the complete month-by-month guide, including FAQs on prior-year defaults and reconciliation:
https://accorppartners.com/blogs/apr/the-apr-deadline-countdown-what-to-do-in-october-november-and-december
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