Reporting your foreign filings got much simpler

What changed

Rule 12 was amended. The statement and undertaking under section 8(1) is filed within six months of filing in India. The duty to keep the Controller informed under section 8(1)(b) is now discharged within three months of the first statement of objections, replacing the old rolling six-month obligation on each new foreign filing. The Controller may now use accessible databases to obtain the information, and new rule 12(5) allows delay in filing Form 3 to be condoned by up to three months on a Form 4 request.

Why it matters

Section 8 non-compliance is a ground of revocation under section 64(1)(m). The old rolling duty was easy to breach across a large family handled by several firms. Form 3 is now effectively filed twice, which is far easier to manage - and there is, for the first time, an express power to condone delay.

Who should care

Anyone with an Indian application that has foreign family members.

What you should do

Run a family audit at the examination report stage and file a consolidated Form 3 that is accurate as at that date. Give one person in India ownership of foreign filing particulars for the whole family.