Periodic SEZ Reporting for GIFT IFSC Units: MPR, SERF and APR Compliance Guide

Once a GIFT IFSC entity obtains its SEZ Letter of Approval (LOA) and moves towards operational status, its SEZ obligations do not end with setup and commencement. Periodic reporting becomes an important part of ongoing GIFT IFSC SEZ compliance. The key recurring reports are the Monthly Performance Report (MPR), Service Exports Reporting Form (SERF) and Annual Performance Report (APR), each serving a different regulatory purpose.

Understanding Periodic SEZ Reporting in GIFT IFSC

Periodic SEZ reporting enables the authorities to monitor the operational performance of IFSC units, including employment, investments, service exports and annual performance. These filings also create an important regulatory history for the entity.

For management, periodic reporting should therefore be integrated with accounting, payroll, investment and regulatory records rather than being treated merely as a portal-filing exercise.

Why Periodic SEZ Reporting Is Important

MPR, SERF and APR together provide a continuing record of an IFSC unit’s performance and operations. Accurate reporting helps maintain consistency between SEZ filings, financial records and actual business activity. It also becomes relevant during regulatory reviews, LOA renewal and exit. Accordingly, IFSC entities should establish clear responsibility and supporting documentation for each periodic filing.

Monthly Performance Report (MPR) for GIFT IFSC Units

The Monthly Performance Report (MPR) is a monthly snapshot of information relating to the SEZ unit, including employment and investments.

The SEZ Compliance FAQ Booklet provides that all IFSC units regulated by IFSCA that have obtained an LOA must submit MPR every month through the SEZ Online portal under the “Prepare Monthly Reports” tab. Importantly, the MPR obligation is linked to obtaining the LOA and is not restricted only to units whose commencement has already been taken on record.

Employment reporting in MPR

Employment is classified into:

• Direct Employment: persons on the direct payroll of the IFSC unit.
• Indirect Employment: contractual, outsourced or temporary personnel, including vendor-provided IT support and similar resources.

For a fund holding a separate SEZ LOA but having no employees of its own, the fund should report NIL direct and indirect employment, while the FME reports its relevant employment figures in its own MPR.

Investment reporting in MPR

The guide clarifies that investment includes expenditure on hard assets such as:

• interiors,
• furniture,
• IT systems, and
• servers.

Capital received from a parent entity or investment received from investors into a fund is not treated as investment for MPR purposes.

If an MPR is missed or contains an error, the SEZ Online portal permits submission or updating for the past three months.

MPR Reporting by Funds in GIFT IFSC

Funds require particular attention because each fund may itself be an SEZ unit with a separate LOA, even though its operations are managed by an FME.

Therefore, an FME should not assume that filing its own MPR automatically satisfies the SEZ reporting requirement of the funds managed by it.

Where the fund does not employ personnel directly or indirectly, it must still file its own MPR showing NIL employment. The FME separately reports the actual employment relating to its own unit.

This distinction is important when maintaining entity-wise SEZ compliance calendars.

Service Exports Reporting Form (SERF)

The Service Exports Reporting Form (SERF) is a monthly summary of invoices generated or issued by an IFSC unit.

Unlike MPR, SERF becomes relevant once the unit’s intimation of commencement has been taken on record by the Administrator (IFSCA) in the SEZ Online portal. Such units must submit SERF every month through the “Service Exports Reporting Form” functionality.

Where commencement has occurred but the intimation is still being processed, SERF must subsequently be filed for all applicable months beginning from the month of commencement once commencement is taken on record.

SERF filing by funds

Where a fund launched by an FME has no export of its own but has a separate SEZ LOA, the fund is required to file a NIL SERF every month. The relevant invoice-wise transaction details are reported in the FME’s SERF.

A missed SERF can be filed for earlier months. However, an important limitation is that an already filed SERF cannot be resubmitted through the portal for correction. Errors should therefore be immediately brought to the notice of the Office of Administrator (IFSCA) by email.

This makes review of invoice-wise information before filing particularly important.

Annual Performance Report (APR) for GIFT IFSC Units

The Annual Performance Report (APR) is the principal annual SEZ reporting requirement.

Under Rule 22(3) of the SEZ Rules, the APR is prepared in Form-I. The information must be authenticated by the authorised signatory of the unit and duly certified by an independent Chartered Accountant or Cost Accountant. The certified APR is then uploaded through an “APR” request on the SEZ Online portal.

Every IFSC unit whose commencement has been taken on record must file APR for each financial year, including the financial year of commencement.

Due date for APR

The APR is required to be submitted within nine months following the close of the financial year. Accordingly, the effective deadline is 31 December of the subsequent financial year. For example, for FY 2026-27, the guide specifies 31 December 2027.

Where a fund has no exports of its own, it must nevertheless submit a NIL APR, while the FME files its APR with the relevant information.

APR compliance also has longer-term significance because APRs become part of the unit’s compliance history and may be relevant for matters such as LOA renewal.

Late Filing and Correction of SEZ Reports

The treatment of missed or incorrect filings differs across reports.

For MPR, the portal allows filing or updating for the previous three months. SERF can also be submitted for past months, but an already submitted SERF cannot be resubmitted for correction. APR can be filed for past financial years, although timely filing is strongly advised.

Non-compliance should therefore be identified and corrected promptly instead of being allowed to accumulate across reporting periods.

Is SOFTEX Applicable to GIFT IFSC Units?

The SEZ Compliance FAQ Booklet specifically clarifies that IFSC units are not required to file the SOFTEX Declaration Form. It refers to the RBI clarification that IFSC units falling within the definition of financial institutions under the IFSCA Act and exporting software to persons outside India are exempt from this requirement.

Conclusion

Periodic SEZ reporting is a core part of ongoing GIFT IFSC compliance. MPR captures monthly operational information, SERF records service-export invoices, while APR provides an independently certified annual performance record.

The key to effective compliance is maintaining entity-wise records, particularly where an FME manages multiple funds with separate LOAs, and reconciling regulatory filings with underlying accounting, employment and business records. Timely and accurate reporting reduces regulatory risk and creates a reliable compliance history for future renewals, reviews and eventual exit.

Frequently Asked Questions

1. Is MPR mandatory even before commencement of operations?

Yes. The guide states that every IFSCA-regulated IFSC unit that has obtained an LOA must submit MPR every month.

2. When does SERF filing start?

SERF becomes applicable once commencement has been taken on record. Reports are then required from the month of commencement onwards.

3. Can an incorrect SERF be revised?

No. The portal does not permit resubmission of an already filed SERF. Errors should be immediately reported to the Office of Administrator (IFSCA).

4. Who must certify the APR?

The APR must be authenticated by the authorised signatory and certified by an independent Chartered Accountant or Cost Accountant.

5. What is the due date for APR?

APR must be submitted within nine months after the close of the financial year, effectively by 31 December of the subsequent financial year.