Post-Incorporation Compliance Checklist for an Indian Subsidiary

Incorporation creates the Indian company, but it does not finish the setup. A foreign-owned subsidiary still needs to organise its records, capital and banking steps, accounting, tax registrations and recurring statutory obligations. The right sequence depends on the company’s structure, activities and the transactions it carries out.

For recurring and event-based deadlines across the year, use our annual compliance calendar for a foreign-owned Indian subsidiary.

When the parent funds the company, keep the bank, share-issue and foreign-investment reporting records together. Our guide to funding an Indian subsidiary from the US explains the main questions to confirm before remitting money. For audit-specific planning, see our guide to audit requirements for a foreign-owned Indian subsidiary.

1. Review the incorporation records

Start with the Certificate of Incorporation and the documents filed to establish the company. Check the legal name, registered-office details, authorised share capital and subscriber/shareholding information against the company’s approved structure.

• Certificate of Incorporation and company identification details.
• PAN and TAN details, where issued through the incorporation process.
• Memorandum and Articles of Association.
• Director, subscriber and shareholding records.
• Board and shareholder resolutions, declarations and filing acknowledgements.

Keep a secure central record set and note any mismatch that needs correction. If the parent company is overseas, agree who will retain originals and who can approve documents for the Indian entity.

2. Make a first-month action list

Use a checklist rather than relying on a single incorporation milestone. For each item, record the responsible person, required documents, due date and evidence that the task is complete.

• Confirm the registered-office verification and other incorporation-related filings that apply.
• Review auditor appointment and other initial corporate actions under the Companies Act.
• Prepare the company’s statutory registers and minute records as required.
• Coordinate bank onboarding and the evidence required by the selected bank.
• Track the subscription money or other initial capital steps in line with the incorporation documents and applicable law.
• Set up bookkeeping, document retention and approval controls from the start.

Deadlines and formalities can depend on the facts and current rules. Ask the company secretary or incorporation adviser to confirm the exact actions and dates for the new company.

3. Coordinate foreign investment and bank records

When the shareholder is outside India, retain clear evidence of the investment and any remittance. Coordinate the bank’s KYC and remittance documentation with the corporate records, and confirm whether any RBI/FEMA reporting is triggered by the transaction.

For example, FC-GPR may be relevant when an Indian company issues equity instruments to a person resident outside India. Other reporting requirements may apply depending on the transaction, instrument, ownership and current rules. Do not treat every form as mandatory for every foreign-owned company.

See the separate guide to FLA Return and transfer-pricing compliance for two important annual reporting topics.

If the company plans to hire employees, review the separate India payroll compliance guide for US companies before the first payroll run. It covers employer setup, payroll records and how to assess PF, ESI and state-level requirements.

4. Check tax and operational registrations

Assess the company’s actual activities before deciding which registrations are required. GST, tax withholding, import-export, local licences and other registrations depend on factors such as the type of supply, employees, location and business model.

• GST: assess registration based on the company’s supplies, locations and applicable rules.
• TDS and income tax: identify withholding obligations, tax payments, returns and recordkeeping that apply to the company’s payments and income.
• Payroll: if the company hires employees, set up payroll and assess the applicable employment-related registrations and statutory deductions.
• Import/export and sector licences: review these if the company’s planned activities require them.

Registration should follow a fact-based assessment; applying for every possible registration can create unnecessary work, while missing a required one can create compliance risk.

5. Establish accounting and internal controls

Set up the chart of accounts, bank reconciliation process, invoice approvals, expense records and intercompany accounting before transactions become difficult to reconstruct. Agree the reporting currency, group reporting format and month-end timetable with the overseas parent.

For cross-border transactions, keep agreements and supporting evidence for management fees, services, royalties, cost allocations, loans and other intercompany arrangements. The tax and FEMA treatment can differ by transaction, so review each arrangement before payments begin.

6. Build a recurring compliance calendar

The calendar should reflect the company’s financial year, transactions, registrations, employee count and sector. It may include:

• Monthly or periodic accounting, GST and tax-withholding tasks, where applicable.
• Payroll processing and employment-related returns, where applicable.
• Corporate records, event-based Registrar of Companies filings and annual filings.
• Statutory audit and income-tax return requirements.
• Transfer-pricing documentation and accountant-report requirements when applicable.
• RBI/FEMA reporting, including FLA Return or transaction-based reporting where required.

Assign each item to a named owner and include reminders for data collection, review and filing—not just the final due date. Revisit the calendar when the company hires staff, begins a new activity, changes shareholding or enters a new cross-border arrangement.

7. Official sources to check

• Ministry of Corporate Affairs — company law, incorporation and Registrar of Companies filing information.
• Reserve Bank of India — foreign investment and FEMA reporting guidance.
• Income Tax Department — current tax forms, returns and reporting guidance.
• GST Portal — GST registration and filing resources.

Rules, forms and due dates can change. Verify current requirements against official guidance and the company’s actual circumstances.

Frequently asked questions

What should a company do after incorporation in India? Start by reviewing the Certificate of Incorporation, PAN and TAN details, constitutional documents, director and shareholder records, and the filing-specific deadlines. Then plan the bank account, share-capital steps, statutory registers, accounting, tax registrations and any applicable FEMA reporting. The exact checklist depends on the company and its activities.

Does every Indian subsidiary need GST registration immediately? Not in every case. GST registration depends on the business activities, turnover, location, type of supply and other applicable rules. Review the facts with a tax professional before deciding whether and when registration is required.

What is FC-GPR and does every foreign-owned company file it? FC-GPR is an RBI reporting form associated with the issue of equity instruments to a person resident outside India. Whether it applies and when it is due depends on the transaction and current FEMA/RBI requirements. It is not a universal filing simply because a foreign parent exists.

What is the FLA Return? The Foreign Liabilities and Assets Return is an annual RBI reporting requirement for Indian entities that have received foreign direct investment or made overseas direct investment, subject to the applicable rules and reporting conditions. Check the current RBI directions and portal guidance for applicability and deadlines.

Does a newly incorporated subsidiary need an auditor? Companies generally need to appoint an auditor in accordance with the Companies Act, 2013. The appointment process and deadline depend on the company’s circumstances and applicable provisions. Confirm the current requirement and record the appointment correctly.

Can the subsidiary wait until it starts earning revenue to maintain accounts? Do not assume that no revenue means no records or filings. Statutory, tax, corporate and transaction-specific obligations may apply even before commercial operations begin. Keep records from incorporation and confirm the obligations relevant to the company.