What Is Form ECB-2?
Form ECB-2 is the return an Indian borrower files with the Reserve Bank of India (RBI) to report the receipt of External Commercial Borrowing (ECB) proceeds and any debt servicing — principal, interest and other charges — during a calendar month. It runs on a monthly cycle, but the obligation is transactional rather than unconditional: paragraph 16(1)(c) of the current ECB framework requires "'Form ECB 2' for reporting receipt of ECB proceeds and debt servicing, within seven calendar days from the end of the month in which the proceeds were received or debt servicing was undertaken." A month in which nothing happened on the loan is not what the paragraph attaches the return to.
The return is not filed directly with the RBI. It is routed through the borrower's designated Authorized Dealer (AD) Category-I bank, which forwards it to the RBI in the format the RBI prescribes. This is a distinct filing channel from the FIRMS portal, which handles a different family of FEMA returns for foreign investment (see FEMA reporting: SMF and FIRMS) — ECB-2 is never uploaded to FIRMS.
Legal Basis
Form ECB-2 reporting is governed by the Foreign Exchange Management (Borrowing and Lending) Regulations under the Foreign Exchange Management Act (FEMA), as substituted by Notification No. FEMA 3(R)(5)/2026-RB dated February 9, 2026, which came into force on its publication in the Official Gazette on February 16, 2026. The notification substituted Schedule I of the earlier Borrowing and Lending Regulations — the ECB framework now sits in this substituted Schedule, and citations should point to the regulation itself rather than to RBI's ECB Master Direction, which restates it.
Paragraph 16(1) of the substituted Schedule sets out the reporting mechanics. Its opening words require eligible borrowers to "submit the following application/return through the designated AD Category I bank in the format provided by the Reserve Bank," and sub-clause (c) fixes the Form ECB-2 deadline at "within seven calendar days from the end of the month in which the proceeds were received or debt servicing was undertaken." An Explanation to the same sub-paragraph broadens what has to be reported: "any event or transaction that alters the outstanding borrowing under an LRN shall be reported in 'Form ECB 2.'" A common error is to read the deadline as seven days from the date of drawdown or the date of the payment itself — it is not. The clock runs from the end of the calendar month, not from the individual transaction date.
Who Must File, and When
Paragraph 1(1) of the substituted Schedule makes "any person resident in India (other than an individual) that is incorporated, established or registered under a Central or State Act" an eligible borrower, subject to that person being permitted to raise ECB under the Act that governs it. The substituted Schedule no longer splits ECB into an automatic route and an approval route; it states one set of conditions, so the reporting obligation is the same for every eligible borrower.
The cadence is monthly rather than quarterly or annual, and it is driven by what happened on the loan. A borrower files Form ECB-2 for each month in which ECB proceeds were received or debt servicing was undertaken, and — under the Explanation to paragraph 16(1) — for any event or transaction that alters the outstanding borrowing under the Loan Registration Number (LRN). Paragraph 16 does not, on its own terms, require a return for a month in which none of that occurred, so a borrower that reports every month regardless is following practice or its bank's instruction rather than the text of the regulation.
Where a borrower has drawn down an ECB in multiple tranches or is servicing more than one ECB, a separate Form ECB-2 is filed against each LRN.
Applies to ECBs Raised Before February 2026, Too
Regulation 1(3) of the February 2026 amendment regulations — the "Short title and commencement" clause, not paragraph 1(3) of the substituted Schedule — extends the new reporting regime beyond loans signed after the change: "External Commercial Borrowings for which a Loan Registration Number (LRN) has been obtained before these regulations coming into effect shall continue in compliance with the then applicable regulations, except reporting which shall be undertaken as per the amended regulations." In practice, a company that raised an ECB in, say, 2023 did not get to keep its old reporting cadence — from the first reporting cycle after 16 February 2026, its Form ECB-2 filings had to move to the seven-calendar-days-from-month-end deadline along with every new borrower.
Form ECB-2 and Revised Form ECB-1 — Keep Them Separate
Form ECB-1 is filed once, before the first drawdown, to obtain the Loan Registration Number — paragraph 10(1) permits a borrower to "drawdown ECB only after obtaining the Loan Registration Number (LRN) from Reserve Bank through the designated AD Category I bank." A "Revised Form ECB-1" is a different, later filing — used only when the terms of an already-registered ECB change (for example, a change in the amount, the lender, or the maturity). Under the same February 2026 notification, a Revised Form ECB-1 follows the identical timing rule as Form ECB-2: paragraph 16(1)(b) requires it "within seven calendar days from the end of the month in which such change was given effect." The two forms serve different purposes — Form ECB-2 is the recurring monthly return on proceeds and debt servicing, while Revised Form ECB-1 is a one-off correction filed only when loan parameters change — but a borrower amending its ECB terms in a month where it also received proceeds or serviced debt may need to file both within the same seven-day window.
Consequences of Missing the Deadline
A borrower that misses the seven-calendar-day deadline does not automatically lose its ECB, but the delay is a reporting contravention under FEMA. Paragraph 16(2) provides that "in case of non-adherence with reporting timelines, the borrower may pay late submission fee as per the guidelines issued by the Reserve Bank in this regard after completing the reporting" — the fee follows the filing rather than gating it, and the amount comes from RBI guidelines that should be confirmed with the AD Category-I bank rather than assumed. Separately, paragraph 16(6) treats a borrower holding an active LRN as an "untraceable borrower" where it fails to submit any specified return for four consecutive quarters or more after the quarter in which a drawdown or debt servicing was scheduled under its last reported Form ECB-1, and the designated AD Category-I bank is satisfied both that neither the borrower nor its auditors, directors or promoters were reachable despite documented attempts at communication, and that the borrower was not operating at its registered office address. Where that happens after a drawdown, paragraph 16(7) requires the AD bank to inform the Reserve Bank and the Directorate of Enforcement. Contraventions that are not resolved through the late-fee route can also be addressed through FEMA compounding, the voluntary mechanism for admitting a foreign exchange contravention and paying a compounding amount to close the matter without adjudication proceedings.
Common Mistakes
- Counting seven days from the transaction, not the month-end. The deadline runs from the end of the calendar month in which proceeds were received or debt was serviced — not seven days from the drawdown date or the repayment date itself.
- Filing through the FIRMS portal. Form ECB-2 is submitted through the AD Category-I bank. FIRMS is the portal for Single Master Form and other foreign-investment reporting, not for ECB returns.
- Assuming an old ECB keeps its old reporting timeline. Regulation 1(3) makes the new seven-calendar-day rule apply to reporting on every outstanding ECB, including those registered years before the February 2026 notification.
- Reading the trigger too narrowly. The return is not limited to scheduled drawdowns and repayments: the Explanation to paragraph 16(1) extends it to any event or transaction that alters the outstanding borrowing under the LRN.
- Confusing Form ECB-2 with Revised Form ECB-1. A change in loan terms needs a Revised Form ECB-1, not a note added to the next Form ECB-2.
Practical Example
An Indian manufacturing company draws down USD 4 million of ECB proceeds on 12 March. It also pays a scheduled interest instalment on an earlier ECB on 20 March. Both events happened in the same calendar month, so a single Form ECB-2 covering March is due through the company's AD Category-I bank within seven calendar days of 31 March — that is, by 7 April. If the company also amends the maturity date of the earlier ECB in April, that change goes into a Revised Form ECB-1 due within seven calendar days of 30 April; an April Form ECB-2 is due only if proceeds were received, debt was serviced, or the outstanding borrowing under the LRN otherwise changed during April.
Frequently Asked Questions
Is Form ECB-2 filed with the RBI directly?
No. It is filed through the borrower's designated AD Category-I bank, which submits it to the RBI in the prescribed format. Borrowers do not upload Form ECB-2 to the FIRMS portal or file it with RBI directly.
What is the exact deadline for Form ECB-2?
Seven calendar days from the end of the month in which the ECB proceeds were received or debt servicing was undertaken, under paragraph 16(1)(c) of the Foreign Exchange Management (Borrowing and Lending) Regulations as substituted by Notification No. FEMA 3(R)(5)/2026-RB. The count runs from month-end, not from the date of the individual transaction.
Is Form ECB-2 due every month, even when nothing happens on the loan?
Paragraph 16(1)(c) attaches the return to the month in which proceeds were received or debt servicing was undertaken, and its Explanation adds any event or transaction that alters the outstanding borrowing under the LRN. The regulation does not itself impose an unconditional monthly return for quiet months. Because banks differ in how they administer this, confirm the position for a nil month with the designated AD Category-I bank.
Do I still have to file Form ECB-2 for an ECB I raised before February 2026?
Yes. Regulation 1(3) of the amending notification lets pre-existing ECBs keep their original commercial terms but requires reporting to follow the amended regulations, so the seven-calendar-day deadline applies to every outstanding ECB regardless of when it was registered.
What happens if Form ECB-2 is filed late?
A late filing is a reporting contravention under FEMA. Under paragraph 16(2) the borrower may pay a late submission fee, per RBI guidelines, after completing the reporting; the amount should be confirmed with the AD Category-I bank rather than assumed. Unresolved contraventions can also be addressed through FEMA compounding.
Is Revised Form ECB-1 the same as Form ECB-2?
No. Form ECB-2 is the recurring monthly return on proceeds and debt servicing. Revised Form ECB-1 is filed only when previously reported ECB parameters change, such as the amount, lender, or maturity — though it follows the same seven-calendar-days-from-month-end deadline.
See also: ECB (External Commercial Borrowing), Authorized Dealer Bank, and FEMA Reporting: SMF and FIRMS.