What is the change? The Foreigners Regional Registration Office in Mumbai has implemented new requirements for late registrations and visa extension applications.  

What does the change mean? A company representative must appear at the Mumbai FRRO with an apology letter when the foreign employee is late with the FRRO registration or visa extension.

  • Implementation timeframe: Immediate.
  • Visas/permits affected: Employment visas.
  • Who is affected: Foreign nationals submitting late FRRO registrations or visa extension applications.
  • Impact on processing times: One day delay in processing.
  • Business impact: Therule imposes an additional burden on businesses by requiring them to send a representative to the FRRO to support late applications and on foreign employees to return the following business day to receive their residence permit or visa.
  • Next steps: Companies with branches in Mumbai should be sure that foreign employees’ FRRO registrations and visa extension applications are completed on time to avoid the new requirements.

Background: The FRRO in Mumbai announced that, effective immediately, it is implementing new procedures intended to deter late FRRO registration and visa extension applications. If a foreign national does not register within the required 14 days or is late in submitting a visa extension application, the Indian employer company must send a representative to accompany the foreign employee to the FRRO and bring an apology letter that explains why the registration or extension application is late. The representative typically should be the same person who has signed the company’s letter of undertaking and other support documents. Also, foreign nationals submitting the late registration or extension application must return the next business day to pick up their resident permits or visas instead of receiving them on the same day, which is the usual practice in Mumbai.

BAL Analysis: Companies operating in Mumbai must take care that foreign employees’ FRRO registrations and visa extension applications are submitted on time. The implementation of the new requirement and process delay in Mumbai is a sign that Indian authorities are cracking down on late filings by foreign nationals and their Indian employers. With this in mind, companies should be aware that these policy changes will likely soon appear at FRROs in other cities. BAL is monitoring other locations in India for implementation of similar policies and will report on any additional regional changes.

This alert has been provided by the BAL Global Practice group and our network provider located in India. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact