Opening a Bank Account for Your Indian Subsidiary: KYC, AD Bank Selection and the FIRC Trail (2026)

Written by the Delhi Legal Company India Entry & FDI Advisory team · Last updated August 2026 · Reviewed against RBI Master Directions, PMLA Rules and FEDAI circulars

Introduction

Your Indian company will be incorporated in two to four weeks. It will not be able to receive a rupee for another two to four after that.

The bank account is the step foreign groups consistently underestimate, and it sits on a dependency chain where every link has a statutory deadline hanging off it. Capital cannot arrive until the account is live. Shares cannot be allotted until capital arrives. FC-GPR cannot be filed until shares are allotted — and that clock is 30 days from allotment, not from the day someone remembers.

The reason it takes so long is not bureaucracy for its own sake. Your Indian company is a customer with a foreign parent, and the bank has to identify the natural persons who ultimately own it. Since 2023 that means tracing anyone holding more than 10% — reduced from 25%. For a group with a fund in the chain, or three layers of holding companies, that is a genuine investigation, and banks run it in rounds.

This guide covers what an AD Category-I bank actually is and why you need one, how to choose, what the KYC pack contains, whether your directors have to travel, and the FIRC trail that everything downstream depends on.

About this guide

Delhi Legal Company works exclusively with foreign companies establishing and operating in India. Bank account opening is where the incorporation timeline most often slips, and where the documents you obtained for incorporation get used a second time — which is why the two workstreams should be planned together.

Where a rule is settled we state it and cite the source. Where practice varies between banks — and it varies a great deal — we say so, because what a particular bank will accept matters as much as what the rule permits.

Primary sources: the Reserve Bank of India for the Master Direction on KYC, the AD Category-I framework, FEMA and FIRMS reporting; the Prevention of Money Laundering Act rules on beneficial ownership; and FEDAI circulars on FIRC issuance.

1. What an AD Category-I bank is, and why it matters

AD Category-I banks are lenders RBI authorises to handle all permissible current and capital account foreign exchange transactions. RBI’s current list names 91 AD Category-I banks as of 18 November 2025.

The distinction matters because a bank that is not an AD Category-I bank cannot do the things a foreign-owned subsidiary needs.

What you will need Why the AD Category-I status is required
Receive equity capital from the parent Capital account transaction under FEMA
FIRC for the inward remittance Only AD Category-I banks issue them
FC-GPR filing support on the FIRMS portal The filing routes through your AD bank
Outward remittance of dividend, royalty or fees Current account transactions requiring AD authorisation
Branch, liaison or project office application Applications are made through the AD Category-I bank
ECB reporting on a parent loan Loan Registration Number and monthly returns route through the AD bank

Foreign subsidiaries must choose an authorized dealer bank to open and operate their accounts. These banks also assist in filing reports via RBI’s FIRMS portal for foreign investments. Choosing the right bank can impact the speed and accuracy of compliance.

1.1 It is a relationship, not a utility

Over the life of an Indian subsidiary, the AD bank is involved in every cross-border movement: capital in, FC-GPR, dividends out, royalty and fee remittances, share transfers, and eventually closure. The bank that processes your first remittance will still be processing your last.

That argues for choosing on capability rather than on branch convenience or the relationship manager who responded first.

2. Choosing the bank

The single biggest variable in how long this takes is which bank you approach.

Question to ask Why it matters
Do you have a dedicated foreign-investment or MNC desk? Banks that handle foreign-owned entities routinely move in days; banks that treat it as an exception take weeks
Have you onboarded a parent from our jurisdiction before? Familiarity with a country’s document formats removes rounds of queries
Will you accept V-CIP for our foreign directors? Determines whether anyone has to travel
Do you support FIRMS and FC-GPR filing? Some banks provide active support; others leave it entirely to you
What is your realistic timeline for our structure? Ask specifically about a multi-layered or fund-owned parent
Who signs off on the UBO determination? Escalation to a central compliance team adds time; a branch-level decision is faster
Do you issue physical FIRCs for FDI remittances? You will need one — see section 7

2.1 Where your parent already banks

If your group’s global bank has an Indian presence with AD Category-I status, start there. The parent’s KYC may already exist within the group, and an existing relationship shortens the beneficial ownership investigation considerably.

This is often the fastest route and it is frequently overlooked, because the Indian incorporation is being run by people who do not know where the group banks.

2.2 Approach more than one

Because timelines vary so much between institutions, and because a bank can decline a structure it is uncomfortable with, running two applications in parallel is a reasonable hedge on a time-critical entry. You are not obliged to proceed with both.

3. Start before incorporation

This is the control that matters most, and it costs nothing.

Engage the bank during document preparation, not after the certificate of incorporation arrives. Ask what they need from the parent, and add it to the attestation run that is already happening for incorporation — see apostille and attestation of parent company documents.

A group that obtains a single attested set for the Registrar and then discovers the bank needs its own certified copies has added a full attestation cycle — two to six weeks — for a document it already had.

3.1 The account is initiated through incorporation, but not activated

The SPICe+ suite includes bank account opening through AGILE-PRO-S. That initiates the process; it does not complete it.

Activation still requires the bank’s own KYC on the company, the signatories and the foreign parent, which runs on the bank’s timetable rather than the Registrar’s. Treating the SPICe+ tick-box as “the account is done” is a common and expensive assumption.

4. The beneficial ownership investigation

This is the part that takes the time, and understanding what the bank is actually doing makes it much easier to get through.

4.1 The 10% threshold

Under the PMLA Rules and RBI’s Master Direction, banks must identify the Ultimate Beneficial Owner — the natural person who ultimately owns or controls the customer entity. For companies, this is a natural person holding more than 10% of shares or voting rights, reduced from 25% in 2023. For partnerships, a natural person with more than 15% of capital or profits. For trusts, the settlor, trustee, protector and each beneficiary holding more than 15%.

The reduction from 25% to 10% materially widened the net. A cap table with six investors each at 12% previously produced no UBO at bank level; it now produces six.

4.2 The bank traces the whole chain

For multi-layered structures — for example a US LLC owned by a Cayman fund managed by a UK GP — the bank traces the ownership chain up to the natural persons. This can be documentation-intensive, and banks often send multiple rounds of queries.

“Multiple rounds” is the operative phrase. The bank does not issue one comprehensive request; it works through the chain layer by layer, and each layer produces a new set of questions.

The way to compress this is to give them the whole chart at the start. Draw the ownership structure from the Indian company up to natural persons, with percentages at every level, and hand it over unprompted with the first application.

4.3 You have already done this analysis — or you should have

The bank’s UBO investigation asks the same question as the Companies Act significant beneficial ownership regime: who ultimately owns this company.

The SBO threshold under Section 90 is also 10%. The chart you build for the bank is substantially the chart you need for Form BEN-2, and the chart you need for the Press Note 3 analysis on the FDI side.

Groups that treat these as three separate exercises do the work three times. Groups that do none of them discover all three at the same moment. See significant beneficial ownership and Form BEN-2.

4.4 Where enhanced scrutiny applies

RBI asks for stricter checks if the shareholder is from a FATF non-cooperative country. Banks may also request proof of beneficial ownership and tax residency.

Enhanced due diligence adds time and additional documentation. Where any part of the ownership chain touches a jurisdiction the bank treats as higher risk, expect a longer process and prepare for it rather than being surprised by it.

5. The documents

Category Documents
The Indian company Certificate of incorporation, memorandum and articles, PAN, TAN, GST registration where obtained, proof of registered office
Authorisation Board resolution approving the account opening and naming the authorised signatories, in the bank’s required form
Signatories and directors Identity and address proof for every signatory and director, photographs, specimen signatures
The foreign parent Certificate of incorporation, charter documents, evidence of shareholding, sometimes a certificate of good standing or net worth certificate
Beneficial ownership UBO declaration identifying natural persons above the threshold, with the ownership chart and supporting documents for each layer
Tax and regulatory FATCA and CRS declarations, tax residency information

5.1 Apostille is not optional here

Submitting non-apostilled documents is a common error. Indian banks are strict about apostille and attestation requirements for foreign documents. A notarized-only passport copy will be rejected — it needs to be apostilled by the competent authority in the issuing country.

Documents issued abroad, such as your certificate of incorporation, must usually be attested. Standard notarisation may not be accepted by Indian banks.

Some banks are stricter than the Registrar. It is not unknown for a document accepted at incorporation to be queried by the bank, which is another reason to ask what the bank wants before the attestation run rather than after.

5.2 The registered office question

A physical business address is essential. Virtual addresses are usually rejected unless accompanied by legal occupancy documentation.

This catches groups that used a serviced or virtual address for incorporation. The Registrar may have accepted it; the bank applies its own standard, and typically wants to see a lease or occupancy right rather than a mail-handling arrangement.

Establish the bank’s position on your address before incorporation, because changing a registered office afterwards is its own filing and its own delay.

5.3 The board resolution, again

Banks generally require the account-opening resolution in their own format, naming signatories and specifying operating instructions — singly, jointly, or by any two.

Where the resolution has to come from the foreign parent’s board rather than the Indian company’s, that is another attestation cycle. Where the Indian company’s own board can pass it, it is a same-week item.

This is why the resolution drafted for incorporation should authorise the bank account opening as part of the same instrument — a point made in the attestation guide and worth repeating, because it is the single most avoidable delay in this process.

6. Do your directors have to travel?

Usually not, and this is better news than most groups expect.

RBI’s V-CIP (Video-based Customer Identification Process) norms allow foreign directors to complete KYC via video call without visiting India. Confirm with your chosen bank whether V-CIP is available for foreign nationals.

Two qualifications on that.

Availability varies by bank. V-CIP is permitted; it is not universally offered to foreign nationals by every institution. Ask specifically, and ask early, because the answer determines whether travel needs to be planned.

It does not replace the documents. V-CIP verifies identity in a video session against documents that still have to be attested and produced. It removes the journey, not the paperwork.

6.1 The resident director point

Where the Indian company has a resident director — and it must, under Section 149(3) — making that person an authorised signatory simplifies both the account opening and day-to-day operation.

The practical arrangement most groups land on is joint operation: the resident director plus a parent nominee, with the mandate requiring both above a threshold. That preserves parent control over material payments without requiring someone overseas for every routine transaction. See the resident director requirement under Section 149(3).

7. FIRC, e-FIRC and FIRA: three different things

This distinction matters more than any other single point in this guide, because getting it wrong stalls your FC-GPR filing.

7.1 What each one is

  What it is Used for
FIRC (physical) Certificate issued by an AD Category-I bank confirming foreign currency was received through official banking channels Restricted to FDI and Foreign Institutional Investment remittances — which is your capital infusion
e-FIRC System-generated electronic FIRC reported to RBI Export receipts
FIRA Foreign Inward Remittance Advice — a lighter proof of credit, often what fintech partner banks provide General confirmation of receipt; not a substitute for an FIRC

7.2 What changed, and when

Banks no longer issue physical FIRCs for export receipts. FEDAI directed member banks to discontinue physical FIRC issuance for export-related payments with immediate effect from 8 June 2016, per FEDAI Circular SPL-09/2016, restricting physical FIRC to FDI and FII remittances only, with a maximum one-year validity.

Since 2016, exporters get a system-generated electronic FIRC reported to RBI, not a physical certificate.

So the position is the reverse of what many people assume. Physical FIRCs were not abolished — they were restricted to exactly the transaction you are doing. Your equity capital infusion is an FDI remittance, and it is one of the cases where a physical FIRC is still issued.

7.3 Why this trips people up

An Indian software services subsidiary receives two kinds of foreign currency: equity capital from the parent, and export receipts from customers. They produce different documents.

The finance team, familiar with e-FIRCs from export receipts, assumes the same applies to the capital infusion. Or the group banks through a fintech partner that issues FIRAs, and presents one for the FC-GPR filing.

FC-GPR requires an FIRC from the AD bank, KYC of the foreign investor, a valuation certificate, board and shareholder resolutions, and the share certificate.

Ask the bank for the FIRC on the day the capital lands. Do not wait until the FC-GPR file is being assembled to discover what you have.

7.4 The one-year validity

Physical FIRCs carry a maximum one-year validity. For a capital infusion followed promptly by allotment and FC-GPR, that is comfortable. For a group that received funds and then delayed allotment, it is another expiry to track alongside the 60-day allotment window.

8. The dependency chain and the clocks

This is the sequence, and each step blocks the next.

# Step Deadline
1 Bank account activated —
2 Capital remitted by the parent —
3 FIRC and KYC obtained from the AD bank Request on the day funds land
4 Valuation certificate, where required Valid 90 days to allotment
5 Shares allotted by the board 60 days from receipt of funds
6 FC-GPR filed on FIRMS 30 days from allotment
7 Share certificates issued Within the prescribed period

Once the account is open, the initial equity capital remittance from abroad triggers FEMA reporting obligations. The company must file Form FC-GPR with the RBI within 30 days of share allotment.

8.1 The trap in step 5

The 60-day clock runs from receipt of funds, not from account opening and not from the board’s convenience.

A group whose account takes six weeks to activate has not lost 60 days — the clock has not started. But a group that remits on the day the account opens and then takes ten weeks to convene a board has a problem, because the funds cease to be a valid share subscription.

8.2 The late submission fee

Late filing of FC-GPR attracts a Late Submission Fee under FEMA.

An LSF is a regularisation mechanism, not a penalty in the compounding sense, and it is far preferable to leaving a filing outstanding. But it is avoidable entirely by starting the FC-GPR file on the day of allotment rather than at the end of the 30 days.

See FC-GPR, FC-TRS and RBI documentation.

9. Account types

For a normal operating subsidiary this is straightforward, but two situations need thought.

Account Suits
Rupee current account Wholly owned subsidiaries and joint ventures incorporated in India — the default
EEFC account Companies with foreign currency earnings that want to hold a permitted portion in foreign currency rather than converting immediately
Escrow or special purpose accounts Transaction-specific arrangements, subject to their own conditions

An EEFC account is worth raising with the bank where the subsidiary will earn export revenue, because it reduces conversion churn on foreign currency receipts. It is an operational efficiency rather than a compliance requirement.

10. Where it stalls

Stall Cause Prevention
Bank engaged only after incorporation Treated as a post-incorporation task Engage during document preparation
Documents attested for the Registrar but not to the bank’s standard Bank applies a stricter test Ask the bank what it needs before the attestation run
Ownership chart produced layer by layer under query Only the immediate parent disclosed initially Hand over the full chart to natural persons unprompted
Registered office is a virtual address Accepted at incorporation, rejected by the bank Confirm the bank’s position before choosing the address
Account-opening resolution has to come from the parent Incorporation resolution did not cover banking Draft the original resolution to cover the full sequence
Foreign director cannot travel and V-CIP not offered Bank’s policy not checked Ask about V-CIP for foreign nationals at the first meeting
FIRA presented instead of FIRC for FC-GPR Confusion between three similar documents Request the FIRC on the day funds land
Enhanced due diligence triggered mid-process A jurisdiction in the chain the bank treats as higher risk Flag the full chain at the outset so the bank scopes correctly
Signatory mandate impractical All signatories overseas Include the resident director in the mandate

11. After the account is open

The relationship continues, and three things need managing.

11.1 Periodic KYC refresh

Banks are required to perform enhanced due diligence for foreign-owned accounts under RBI guidelines. This includes periodic KYC updates and verification of beneficial ownership.

KYC is refreshed on a cycle, and a refresh request arriving unexpectedly can freeze account operations if it is not answered. Keep the attested pack current and treat a refresh request as urgent.

11.2 Changes at parent level

A funding round, a secondary sale or a restructuring at the parent changes the UBO position for the Indian company. The bank needs to know, and so does the Companies Act SBO filing.

A standing instruction at group level — notify Indian compliance of any cap table change — serves both.

11.3 Every outward remittance

Dividend, royalty, management fee, interest: each requires the tax documentation before the bank releases funds. A Tax Residency Certificate covering the period, Form 10F filed electronically, the relevant declarations, and the prescribed remittance forms with a chartered accountant’s certificate above the threshold.

The bank will not process without the acknowledgement. See repatriating profits from India and TDS on payments to your foreign parent.

12. Two situations, worked through

Scenario A — The group that planned it

A UK group targets an India launch in ten weeks. In week one, alongside drafting the incorporation documents, it approaches two AD Category-I banks. One has an MNC desk and has onboarded UK parents before; it confirms V-CIP is available for foreign directors.

The board resolution is drafted to cover incorporation, subscription, account opening and capital remittance in one instrument. The bank is asked what it needs from the parent, and those documents go into the same attestation run. A full ownership chart to natural persons is handed over with the application.

Result. Account activated within two weeks of incorporation. Capital remitted, FIRC requested the same day, allotment at a board meeting the following week, FC-GPR filed inside 30 days.

Scenario B — The group that did not

A group incorporates first and approaches a bank afterwards, choosing the one nearest its office.

What happened. The bank had no MNC desk. It asked for the parent’s documents, which had been attested for the Registrar but not in the form the bank wanted — a fresh attestation cycle. The ownership chart was produced only as far as the immediate Cayman parent; the bank came back three times as it worked up the chain to the fund’s investors. The registered office was a serviced address and the bank asked for occupancy documentation. The account-opening resolution had to come from the parent’s board, which met monthly.

Result. Eleven weeks from incorporation to an operating account, against a plan of three.

What would have changed it. Every one of those items was knowable in week one.

13. Twelve mistakes

  1. Engaging the bank after incorporation rather than during document preparation.
  2. Assuming SPICe+ opened the account. It initiates; the bank activates.
  3. Choosing on branch convenience rather than on whether the bank has a foreign-investment desk.
  4. Disclosing only the immediate parent and letting the bank work up the chain in rounds.
  5. Using the 25% UBO threshold. It was reduced to 10% in 2023.
  6. Submitting notarised-only documents. Indian banks require apostille; a notarised passport copy will be rejected.
  7. Using a virtual registered office without occupancy documentation.
  8. A resolution that authorises incorporation but not banking, forcing a second attestation cycle.
  9. Not asking about V-CIP, and planning travel that was unnecessary.
  10. Presenting a FIRA or e-FIRC for FC-GPR when the FDI remittance produces a physical FIRC.
  11. Requesting the FIRC weeks after the remittance rather than on the day.
  12. Excluding the resident director from the signatory mandate, leaving routine payments dependent on someone overseas.

14. Checklist

Before incorporation

  • Group’s existing global banking relationships checked for an Indian AD Category-I presence
  • Two AD Category-I banks approached and compared on foreign-investment capability
  • V-CIP availability for foreign nationals confirmed
  • Bank’s document list obtained and merged into the attestation run
  • Bank’s position on the proposed registered office confirmed
  • Ownership chart drawn to natural persons with percentages at each level
  • Board resolution drafted to cover incorporation, subscription, account opening and capital remittance

Application

  • Company documents: certificate of incorporation, MOA and AOA, PAN, TAN, proof of registered office
  • Account-opening resolution in the bank’s format, naming signatories and operating instructions
  • Resident director included in the signatory mandate
  • KYC for every signatory and director, apostilled where issued abroad
  • Parent documents: certificate of incorporation, charter documents, shareholding evidence
  • UBO declaration with the full chart, covering everyone above 10%
  • FATCA and CRS declarations completed
  • Higher-risk jurisdictions in the chain flagged proactively

On funding

  • FIRC requested from the AD bank on the day funds land
  • Investor KYC obtained from the bank at the same time
  • Valuation certificate confirmed valid to the allotment date
  • Board meeting convened to allot within 60 days of receipt of funds
  • FC-GPR file opened on the day of allotment; filed within 30 days
  • Share certificates issued and the register of members updated

Ongoing

  • Attested document pack kept current for KYC refresh
  • Standing instruction at group level to notify Indian compliance of cap table changes
  • Remittance documentation process established: TRC, Form 10F, declarations, CA certificate

Incorporating and wondering why nothing can move?

It is almost always the bank, and almost always because it was engaged too late. Tell us your group structure and where your parent banks and we will tell you which AD banks are likely to move quickly on your profile, what they will ask for, and how to fold it into the attestation run you are already doing.


15. Frequently asked questions

Q1. What is an AD Category-I bank and why do we need one?

AD Category-I banks are banks the RBI authorises to handle all permissible current and capital account foreign exchange transactions. RBI’s list named 91 such banks as of 18 November 2025. You need one because only they can receive your equity capital as a capital account transaction, issue the FIRC, support FIRMS and FC-GPR filing, and process outward remittances of dividend, royalty and fees.

Q2. How long does it take to open the account?

Realistically two to four weeks after incorporation where the bank has a foreign-investment desk and the documents are ready, and considerably longer where neither is true. The variable is the beneficial ownership investigation on the foreign parent, which banks run in rounds. Engaging the bank during document preparation rather than after incorporation is the single biggest compression.

Q3. Doesn’t SPICe+ open the bank account for us?

It initiates the process through AGILE-PRO-S; it does not complete it. Activation requires the bank’s own KYC on the company, the signatories and the foreign parent, which runs on the bank’s timetable rather than the Registrar’s. Treating the SPICe+ tick-box as a completed account is a common and expensive assumption.

Q4. What is the beneficial ownership threshold for bank KYC?

More than 10% of shares or voting rights for companies, reduced from 25% in 2023 under the PMLA Rules and RBI’s Master Direction. For partnerships it is more than 15% of capital or profits, and for trusts the settlor, trustee, protector and each beneficiary holding more than 15%. The bank traces multi-layered structures up to the natural persons.

Q5. How do we speed up the beneficial ownership check?

Hand over the complete ownership chart, from the Indian company up to natural persons with percentages at every level, unprompted with the first application. Banks otherwise work up the chain layer by layer, issuing a new set of queries at each level. The same chart also serves your Form BEN-2 analysis and your Press Note 3 assessment.

Q6. Will notarised documents be accepted?

Generally not. Indian banks are strict about apostille and attestation for foreign documents, and a notarised-only passport copy will be rejected — it needs to be apostilled by the competent authority in the issuing country, or legalised where the country is not a Hague member. Some banks apply a stricter standard than the Registrar did at incorporation.

Q7. Do our foreign directors need to travel to India?

Usually not. RBI’s V-CIP norms allow foreign directors to complete KYC by video call without visiting India. Availability varies by bank, so confirm it specifically and early. Note that V-CIP verifies identity against documents that still have to be attested — it removes the journey, not the paperwork.

Q8. Can we use a virtual office as our registered address?

For the bank, usually not without supporting occupancy documentation. Virtual addresses are commonly rejected unless accompanied by a lease or legal occupancy right. This catches groups whose serviced address was accepted at incorporation, because the bank applies its own standard. Confirm the bank’s position before choosing the address.

Q9. What is the difference between an FIRC, an e-FIRC and a FIRA?

An FIRC is a certificate from an AD Category-I bank confirming foreign currency was received through official banking channels, now restricted to FDI and FII remittances with a maximum one-year validity. An e-FIRC is the system-generated electronic version used for export receipts. A FIRA is a lighter Foreign Inward Remittance Advice, often issued by fintech partner banks, and is not a substitute for an FIRC.

Q10. Which one do we need for FC-GPR?

The FIRC from the AD bank. Your equity capital infusion is an FDI remittance, and physical FIRC issuance was specifically retained for FDI and FII remittances when FEDAI discontinued it for export receipts in June 2016. Request it on the day the capital lands rather than when the FC-GPR file is being assembled.

Q11. Why do we get e-FIRCs for our customer receipts but need a FIRC for capital?

Because they are different transaction types. FEDAI Circular SPL-09/2016 discontinued physical FIRC for export-related payments from 8 June 2016 and restricted it to FDI and FII remittances. A software services subsidiary receiving both customer payments and parent capital will therefore see two different documents for two different flows.

Q12. What are the deadlines after the money arrives?

Shares must be allotted within 60 days of receipt of funds from the non-resident investor, and Form FC-GPR filed within 30 days of allotment through the RBI FIRMS portal. Where a valuation certificate is required it must not be more than 90 days old at allotment, so three clocks interact and the binding constraint is whichever expires first.

Q13. What happens if we file FC-GPR late?

Late filing attracts a Late Submission Fee under FEMA. That is a regularisation mechanism and is far preferable to leaving the filing outstanding, but it is entirely avoidable by opening the FC-GPR file on the day of allotment rather than at the end of the 30 days.

Q14. Who should be on the signatory mandate?

Include the resident director, who the company must have in any event under Section 149(3). The arrangement most groups settle on is joint operation — the resident director plus a parent nominee, with both required above a threshold — which preserves parent control over material payments without needing someone overseas for routine transactions.

Q15. What documents does the bank need from the foreign parent?

Certificate of incorporation, charter documents, evidence of shareholding in the Indian company, and a beneficial ownership declaration with the supporting chain. Some banks also request a certificate of good standing or a net worth certificate. All foreign-issued documents need apostille or legalisation.

Q16. Does the KYC end once the account is open?

No. Banks perform periodic KYC refresh for foreign-owned accounts, including re-verification of beneficial ownership, and a refresh request that goes unanswered can freeze account operations. Keep the attested pack current, and treat any change at parent level as something the bank needs to know about.

Q17. Should we approach more than one bank?

On a time-critical entry, yes. Timelines vary substantially between institutions and a bank can decline a structure it is uncomfortable with. Running two applications in parallel is a reasonable hedge, and you are not obliged to proceed with both. Start with any bank your group already uses globally that has an Indian AD Category-I presence.

Q18. What is an EEFC account and do we need one?

An Exchange Earners’ Foreign Currency account lets a company hold a permitted portion of its foreign currency earnings without converting immediately. It suits a subsidiary earning export revenue and reduces conversion churn. It is an operational efficiency rather than a compliance requirement, and worth raising with the bank if the business will invoice overseas customers.