India Compliance Roundup: May — Key Deadlines, Filings & Regulatory Updates

Why May Is a Critical Compliance Month for Foreign-Owned Indian Companies

May sits at the intersection of two financial years in India. The previous financial year (FY 2024-25) ended on 31 March 2025, and May is when many of its wrap-up filings come due — Q4 TDS returns, LLP annual returns, and foreign company annual filings. Simultaneously, monthly GST and TDS obligations for FY 2026-27 continue without pause.

For foreign-owned Indian companies, May carries an additional burden: the Form FC-4 deadline for foreign companies with a place of business in India. Missing any of these deadlines triggers automatic penalties that compound daily, making a well-organized compliance calendar indispensable.

This roundup covers every major deadline for May 2025, verified against current government notifications. Whether you operate a private limited company, LLP, or a branch of a foreign entity, use this as your month-at-a-glance compliance checklist.

GST Compliance Deadlines in May 2025

The Goods and Services Tax regime demands monthly attention from most businesses. May 2025 carries several GST filings tied to April 2025 transactions.

GSTR-7 and GSTR-8 — Due 10 May

GSTR-7 covers TDS deducted under GST by government departments and specified entities. GSTR-8 applies to e-commerce operators collecting TCS. Both are due by the 10th of the following month, making the May deadline 10 May 2025 for April data.

GSTR-1 — Due 11 May

Monthly filers must submit GSTR-1 (outward supply details) for April 2025 by 11 May 2025. This return captures all B2B and B2C invoices, credit notes, debit notes, and export invoices issued during April. Accurate GSTR-1 filing is critical because your buyers rely on it for their Input Tax Credit claims.

IFF (Invoice Furnishing Facility) — Due 13 May

Taxpayers under the QRMP (Quarterly Return Monthly Payment) scheme have the option to upload their April 2025 B2B invoices through the Invoice Furnishing Facility by 13 May. While optional, filing IFF ensures your buyers can claim their ITC in real time rather than waiting for your quarterly GSTR-1.

GSTR-5 and GSTR-6 — Due 13 May

Non-resident taxable persons file GSTR-5, while Input Service Distributors file GSTR-6 by 13 May for the preceding month. Foreign companies operating in India through a temporary registration should pay close attention to the GSTR-5 deadline.

GSTR-3B — Due 20 May

The summary return with tax payment (GSTR-3B) for April 2025 is due by 20 May 2025 for monthly filers. This is the return where you actually pay your GST liability for the month. Late filing attracts a fee of INR 50 per day (INR 25 CGST + INR 25 SGST) for returns with tax liability, capped at INR 5,000, plus interest at 18% per annum on any outstanding tax amount.

QRMP Tax Payment — Due 25 May

Quarterly filers under the QRMP scheme must pay their April tax liability by 25 May 2025 using Form GST PMT-06. While the quarterly return itself is not due until July, the monthly tax payment obligation remains.

Form ITC-03 — Due 31 May

Businesses that opted into the Composition Scheme for FY 2026-27 must file Form ITC-03 by 31 May to reverse all Input Tax Credits on stock and capital goods as of 31 March 2025. This is a one-time filing with significant financial implications.

TDS and TCS Compliance in May 2025

May carries two critical TDS deadlines — a monthly deposit and the quarterly return for Q4 of the previous financial year.

TDS/TCS Deposit for April — Due 7 May

All TDS deducted and TCS collected during April 2025 must be deposited with the government by 7 May 2025. This applies to every deductor — companies, firms, and individuals subject to audit. The penalty for late deposit is interest at 1.5% per month from the date of deduction to the date of actual deposit.

TCS Return for Q4 (Jan-Mar) — Due 15 May

The quarterly TCS return (Form 27EQ) for Q4 of FY 2024-25 (January to March 2025) is due by 15 May 2025. This captures all TCS collected during the final quarter of the previous financial year.

Q4 TDS Returns — Due 31 May

The quarterly TDS returns for Q4 (January to March 2025) of FY 2024-25 are due by 31 May 2025. The three forms to file are:

• Form 24Q: TDS on salary payments
• Form 26Q: TDS on non-salary payments to residents (interest, professional fees, rent, contract payments)
• Form 27Q: TDS on payments to non-residents and foreign companies — critical for companies making payments to foreign parent entities under Section 195

Late filing of TDS returns attracts a fee of INR 200 per day under Section 234E, capped at the total TDS amount for the quarter. Additionally, Section 271H imposes a penalty of INR 10,000 to INR 1,00,000 for returns filed after the due date.

For foreign-owned subsidiaries, Form 27Q is particularly important. Every payment to the parent company — whether management fees, royalties, technical service fees, or inter-company loan interest — must be reported here. Errors in Form 27Q can trigger scrutiny during transfer pricing assessments.

TDS Certificates for Q4 — Due 30 May

TDS certificates (Form 16A) for Q4 non-salary deductions must be issued to deductees by 30 May 2025. For salary TDS, Form 16 is due by 15 June 2025.

PF, ESI, and Labour Law Compliance in May 2025

Companies with employees in India must meet their provident fund and insurance obligations every month without exception.

EPF Contribution — Due 15 May

Employers must deposit Employee Provident Fund contributions for April 2025 by 15 May 2025 through the EPFO portal. The employer contributes 12% of basic salary (split between EPF and EPS), and the employee's 12% share must also be deposited. Late deposit attracts damages ranging from 5% to 25% of the arrears, depending on the delay period, plus interest at 12% per annum.

The Electronic Challan cum Return (ECR) must be generated and filed through the EPFO portal by the same date.

ESI Contribution — Due 15 May

Employers covered under the Employee State Insurance Act must deposit ESI contributions for April 2025 by 15 May 2025. The current contribution rate is 0.75% for employees and 3.25% for employers on gross wages up to INR 21,000 per month.

ESI Half-Yearly Return — Due 12 May

In addition to the monthly contribution, employers must file their half-yearly Return of Contributions (RC) for October 2024 through March 2025 by 12 May 2025. This is a semi-annual compliance obligation that covers the entire second half of FY 2024-25.

MCA and ROC Filings in May 2025

The Ministry of Corporate Affairs has several May deadlines that are especially relevant for foreign-owned entities.

LLP Form 11 (Annual Return) — Due 30 May

Every Limited Liability Partnership registered in India must file its Annual Return in Form 11 by 30 May 2025 for FY 2024-25. This applies regardless of whether the LLP conducted any business during the year. The form captures details of partners, their contributions, and a summary of the LLP's management structure.

Late filing attracts a penalty of INR 100 per day with no maximum cap, meaning delays can become extremely expensive. An LLP with foreign partners should ensure the DPIN/DIN of all designated partners is active and their KYC is current before filing.

Form FC-4 (Foreign Company Annual Return) — Due 30 May

Foreign companies that have established a place of business in India — whether through a branch office, liaison office, or project office — must file Form FC-4 with the Registrar of Companies by 30 May 2025 (within 60 days of the financial year end). This form requires details of the foreign company's operations in India, financial statements, and compliance status.

The penalty for late filing of FC-4 is INR 50,000, plus INR 1,000 per day for continued delay — significantly steeper than most MCA penalties. Given these stakes, foreign companies should begin preparing their FC-4 data well before the deadline.

Form PAS-6 (Reconciliation of Share Capital Audit) — Due 30 May

Companies with dematerialised securities must file their half-yearly Reconciliation of Share Capital Audit Report in Form PAS-6 by 30 May 2025 for the half-year ending 31 March 2025. This applies to companies that have issued shares in demat form and is verified by a practicing company secretary.

FEMA and RBI Compliance Actions for May

While May does not carry a specific FEMA deadline, companies with foreign investment should use this month strategically for RBI compliance preparation.

FC-GPR Reconciliation

Review all share allotments made during Q4 (January-March 2025). If any FC-GPR filings are pending, complete them immediately. FC-GPR must be filed within 30 days of share allotment to a foreign investor, and delays attract RBI compounding penalties under FEMA that can reach up to three times the amount involved.

FLA Return Preparation

The FLA Return is due by 15 July. May is the ideal time to begin compiling unaudited financial data for the FLA Return, which requires details of all foreign liabilities (equity, debt, trade credits) and foreign assets. Companies that start early avoid the scramble in June-July when audit preparations also intensify.

External Commercial Borrowing Compliance

If your company has any External Commercial Borrowings (ECBs), verify that all monthly ECB-2 returns have been filed through the RBI's FIRMS portal. ECB-2 returns are due by the 7th of every month for the preceding month.

Income Tax Compliance in May 2025

Beyond TDS-specific obligations, May has broader income tax compliance implications.

Advance Tax Status Check

While no advance tax installment falls in May, companies should use this period to prepare their preliminary tax projections for FY 2026-27. The first advance tax installment (15% of estimated annual corporate tax) is due on 15 June 2025. Companies opting for the concessional tax rate under Section 115BAA pay an effective rate of 25.17%, while those retaining old-regime benefits face a 30% base rate plus surcharge and cess.

Tax Audit Planning

May is also when companies should begin identifying and appointing their statutory auditor for the financial year audit. The audit report (Form 3CA/3CD) for FY 2024-25 is due by 31 October 2025, and companies subject to transfer pricing audit (Form 3CEB) face the same deadline. Starting early ensures adequate time for documentation, especially for inter-company transactions that require arm's length benchmarking.

Practical Compliance Checklist for May 2025

Use this action-oriented checklist to ensure nothing falls through the cracks:

Week 1 (1-7 May)

• Deposit TDS/TCS collected in April by 7 May
• Begin compiling Q4 TDS data for return preparation

Week 2 (8-15 May)

• File GSTR-7 and GSTR-8 by 10 May
• File GSTR-1 by 11 May
• Upload IFF and file GSTR-5/GSTR-6 by 13 May
• Deposit EPF and ESI contributions by 15 May
• File TCS return (Form 27EQ) for Q4 by 15 May
• File ESI half-yearly return by 12 May

Week 3 (16-25 May)

• File GSTR-3B by 20 May and pay GST liability
• Pay QRMP tax through GST PMT-06 by 25 May

Week 4 (26-31 May)

• Issue Form 16A certificates for Q4 by 30 May
• File LLP Form 11 by 30 May
• File Form FC-4 (foreign company) by 30 May
• File Form PAS-6 by 30 May
• File Q4 TDS returns (Forms 24Q, 26Q, 27Q) by 31 May
• File Form ITC-03 (Composition Scheme) by 31 May if applicable

Penalty Quick-Reference for May Deadlines

Common Mistakes Foreign Companies Make in May

Based on our experience supporting foreign-owned Indian subsidiaries, these are the most frequent May compliance errors:

Ignoring Form 27Q

Many companies file Forms 24Q and 26Q on time but overlook Form 27Q, which captures TDS on payments to non-residents. Every management fee, royalty payment, or inter-company service charge paid to the foreign parent during Q4 must be reported in Form 27Q. Missing this filing not only triggers the INR 200/day penalty but also creates a disconnect between your TDS records and transfer pricing documentation — a red flag during assessment.

Filing Form FC-4 Without Updated Financial Data

Foreign companies often file Form FC-4 with stale or estimated financial data because audited figures are not yet available in May. While the MCA accepts unaudited data, significant discrepancies between the FC-4 and subsequent audited financials can trigger queries. Use the best available management accounts and flag any material estimates in the supporting documentation.

Missing the ESI Half-Yearly Return

The ESI half-yearly Return of Contributions due by 12 May is frequently missed because it is a semi-annual obligation buried within routine monthly deposits. Unlike the monthly contribution deposit, this return requires a separate filing covering the entire October-March period and captures employer and employee details for all covered employees.

Underestimating LLP Form 11 Complexity

LLPs with foreign designated partners sometimes struggle with Form 11 because the DPIN/DIN of all partners must be active and KYC-compliant before filing. If a foreign partner's KYC has lapsed, the Form 11 filing will be rejected by the MCA portal. Verify partner KYC status at least two weeks before the 30 May deadline to allow time for remediation.

Key Takeaways

• May carries 15+ compliance deadlines spanning GST, TDS, EPF/ESI, and MCA filings — with cumulative penalties that can reach several lakhs if ignored
• Q4 TDS returns (Form 24Q, 26Q, 27Q) due 31 May are particularly important for foreign-owned subsidiaries, as Form 27Q captures all payments to the parent company under Section 195 and feeds into transfer pricing documentation
• Foreign companies must file Form FC-4 by 30 May — with penalties of INR 50,000 plus INR 1,000 per day, this is one of the most expensive filings to miss
• LLP annual returns (Form 11) also fall due on 30 May — the INR 100/day penalty has no cap, making indefinite delays extremely costly
• Begin preparing for June and July deadlines now — the first advance tax installment (15% of estimated tax) is due 15 June, and the FLA Return is due 15 July, both requiring early preparation

For ongoing compliance support across all monthly deadlines, explore our annual compliance service. If you are evaluating India market entry and need to understand the full compliance burden, see our 12 compliance deadlines foreign companies miss or consult our FEMA and RBI compliance service for foreign investment reporting.