Foreign Investment Advisory for FinTech Companies

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India has become one of the fastest-growing FinTech markets in the world, supported by the rapid adoption of digital payments, online lending, investment platforms, InsurTech solutions, RegTech services and financial software. This growth has attracted significant interest from foreign venture capital funds, private equity investors and global financial institutions seeking opportunities in India’s expanding digital financial ecosystem. Foreign investment can help FinTech companies access capital, advanced technology, international expertise and wider business networks.

However, investing in a FinTech company involves more complex legal requirements than investing in an ordinary technology business. FinTech companies may operate in regulated areas such as payments, lending, insurance or securities services. Therefore, the investment may be governed by FEMA, the FDI Policy, the Companies Act, RBI regulations and directions issued by SEBI, IRDAI or PFRDA. Before accepting investment, the company must identify its business activity, applicable sectoral cap, entry route, licensing requirements, beneficial ownership and RBI reporting obligations.

In this article, CA Manish Mishra talks about Foreign Investment Advisory for FinTech Companies.

What Is Foreign Investment Advisory for FinTech Companies?

Foreign investment advisory refers to professional guidance provided to an Indian FinTech company, its founders and foreign investors regarding the structuring, receipt, allotment and reporting of foreign investment. The advisory process begins by studying the actual business operations of the company. The advisor examines whether the FinTech company is only providing software services or is directly involved in lending, payments, investment advisory, insurance distribution, customer fund management or another regulated financial activity.

Based on this analysis, the appropriate foreign investment route is identified. The advisor also determines whether the proposed investment can be received under the automatic route or whether prior approval from the Government of India, RBI or another regulator is necessary. Foreign investment advisory also includes reviewing the investment instrument, valuation, investor eligibility, ultimate beneficial ownership, pricing guidelines, transaction documents and RBI reporting obligations. It therefore covers the complete transaction from the initial investment proposal to post-investment compliance.

Why Business Model Classification Is Important for FinTech Companies

The term “FinTech” is not treated as a separate sector under India’s Foreign Direct Investment Policy. The foreign investment treatment of a FinTech company depends on the actual activity carried out by it. For example, a company developing accounting software for banks may be treated as a technology service provider. On the other hand, a company operating a digital lending application may fall within the financial services sector even if it describes itself as a technology platform.

Similarly, a company that only provides payment technology may be classified differently from a company that handles customer funds, settles payments or operates a payment system. Therefore, the description mentioned in the company’s incorporation documents is not sufficient to determine the FDI route. Regulators, investors and authorised dealer banks may examine the company’s agreements, customer journey, revenue model, fund flow, decision-making powers and regulatory licences. A detailed business-model review is therefore the first and most important step in foreign investment advisory.

Legal Context Governing Foreign Investment in FinTech Companies

Foreign investment in Indian FinTech companies is regulated through multiple laws and regulatory frameworks. These laws must be considered together because compliance under one law does not automatically satisfy the requirements of another law.

Foreign Exchange Management Act, 1999

The Foreign Exchange Management Act, 1999, commonly known as FEMA, is the principal law governing foreign exchange transactions in India. It regulates investments made by persons resident outside India in Indian companies and limited liability partnerships.

FEMA prescribes the permitted modes of investment, eligible instruments, payment methods, pricing requirements, reporting obligations and transfer conditions. It also governs the repatriation of investment proceeds and the consequences of delayed or incorrect compliance. A FinTech company receiving foreign investment must ensure that the investment is permitted under FEMA and is reported to the RBI through the prescribed forms.

Foreign Exchange Management Non-Debt Instruments Rules

The Foreign Exchange Management (Non-Debt Instruments) Rules regulate foreign investment in equity instruments, limited liability partnerships and other non-debt instruments. These rules explain the sectors in which foreign investment is allowed, the applicable entry routes and the restrictions attached to different business activities.

They also contain provisions relating to investment instruments, beneficial ownership, downstream investment and transfer of securities. FinTech companies must examine these rules carefully because the foreign investment treatment may differ depending on whether the company is engaged in regulated financial services, technology services or an activity that is not fully regulated.

Consolidated FDI Policy

The Consolidated Foreign Direct Investment Policy is issued by the Department for Promotion of Industry and Internal Trade. It provides sector-wise foreign investment limits, automatic-route thresholds, government approval requirements and performance conditions. The FDI Policy must be read along with press notes and amendments issued by the government from time to time.

A transaction that was permitted under the automatic route earlier may become subject to additional conditions after a policy change. Therefore, the foreign investment position should be verified at the time of signing and again before completing the investment.

Companies Act, 2013

The Companies Act, 2013 regulates the corporate process through which an Indian company issues securities to a foreign investor. Depending on the structure, the company may be required to comply with provisions relating to private placement, preferential allotment, rights issue, board approvals, shareholder approvals and return of allotment.

The company must also issue share certificates, update its statutory registers and amend its articles of association where investor rights are incorporated into the company’s constitutional documents. Compliance under FEMA and the Companies Act must be completed separately. Filing an RBI form does not replace the requirement to file the applicable form with the Registrar of Companies.

Sector-Specific Regulations

A FinTech company may also be regulated by the Reserve Bank of India, Securities and Exchange Board of India, Insurance Regulatory and Development Authority of India, Pension Fund Regulatory and Development Authority or another sector regulator. For example, a payment system operator may require RBI authorisation, while an investment adviser may require SEBI registration.

An insurance web aggregator or insurance broker may require registration from IRDAI. Foreign investment approval does not replace these regulatory licences. A company may be eligible to receive foreign investment but may still be prohibited from undertaking a regulated activity without the appropriate licence.

Foreign Investment in Pure Technology FinTech Companies

A FinTech company that only develops software, provides cloud infrastructure, offers cybersecurity solutions or supplies financial technology tools to banks and regulated institutions may generally be treated as an information technology service provider. Such companies may ordinarily receive up to 100% foreign investment under the automatic route because information technology services generally do not carry a specific FDI restriction.

However, the company must genuinely remain a technology provider. It should not independently sanction loans, provide investment advice, accept deposits, manage customer funds or operate a payment system without the required regulatory approval. The company’s agreements should clearly state that the regulated financial institution remains responsible for the financial service, customer relationship and regulatory compliance.

Foreign Investment in RBI-Regulated Financial Services

Foreign investment is generally permitted up to 100% under the automatic route in other financial services where the activity is regulated by the RBI, SEBI, IRDAI, PFRDA or another recognised financial regulator. This permission remains subject to the applicable licensing, capital, ownership, governance and operational conditions imposed by the relevant regulator.

For example, even where 100% foreign investment is permitted, the regulator may examine whether the foreign investor or promoter satisfies fit-and-proper requirements. The regulator may also prescribe minimum capital, board composition, local management or change-in-control conditions. Where the financial activity is not regulated, only partially regulated or where there is uncertainty regarding the regulatory authority, prior government approval may be required.

Foreign Investment in Payment Companies

FinTech companies engaged in payment-related activities require careful classification. A company may operate as a payment gateway, payment aggregator, prepaid payment instrument issuer or payment system operator. A payment gateway that only provides technological infrastructure may be treated differently from a payment aggregator that receives customer payments and settles funds with merchants. Payment companies may require RBI authorisation under the Payment and Settlement Systems Act and applicable RBI directions. They may also be required to maintain minimum net worth, escrow accounts, merchant due diligence systems and grievance mechanisms.

Before accepting foreign investment, a payment company should examine whether the transaction will result in a change in ownership or control. Where regulatory approval is required for such a change, the investment should not be completed without obtaining the necessary permission. The foreign investor should also review the company’s settlement system, customer fund flow, merchant onboarding process, data localisation practices and outsourcing arrangements.

Foreign Investment in Digital Lending Platforms

Digital lending businesses are among the most closely regulated areas of the FinTech sector. A digital lending platform may operate as an RBI-regulated entity or as a lending service provider working with a bank or non-banking financial company. Where the FinTech company lends from its own balance sheet, it may require registration as an NBFC or another appropriate financial institution. A company cannot avoid licensing merely by describing its loans as technology-enabled services.

Where the company works as a lending service provider, the regulated bank or NBFC remains responsible for the outsourced activity. The agreement should clearly define the responsibilities of the lending service provider, including customer acquisition, loan servicing, data handling and grievance redressal. Foreign investors should review whether loans are disbursed directly between the regulated lender and the borrower, whether repayments are routed correctly and whether the FinTech company exercises excessive control over credit decisions. The investor should also examine default loss guarantee arrangements, collection practices, customer consent, annual percentage rate disclosure and access to borrower data.

Foreign Investment in Non-Banking Financial Companies

A FinTech company operating as an NBFC may generally receive foreign investment under the automatic route, subject to RBI regulations and the conditions applicable to regulated financial services. However, the company must continue to satisfy the minimum net-owned fund, prudential, governance and reporting requirements applicable to its category of NBFC.

An investment resulting in a substantial change in shareholding, management or control may require prior approval from the RBI. The company should therefore examine the proposed rights of the foreign investor, including board nomination rights, veto rights and management control. The transaction should not be completed merely on the assumption that the automatic FDI route eliminates the need for RBI approval.

Foreign Investment in Wealth-Tech and Securities Platforms

Wealth-tech companies may provide stock broking, portfolio management, investment advisory, research analysis, mutual fund distribution or technology services. A company directly providing regulated securities-market services must obtain the appropriate registration from SEBI. The applicable foreign investment treatment depends on the category of intermediary and the conditions prescribed by the FDI Policy and SEBI regulations.

Foreign investors should verify whether the company is merely providing technology to a registered intermediary or is itself providing regulated financial advice and executing transactions. The investor should also examine client money handling, investor grievance systems, research disclosures, suitability assessments and conflicts of interest.

Foreign Investment in InsurTech Companies

An InsurTech company may operate as a technology service provider, insurance broker, web aggregator, corporate agent or another insurance intermediary. Where the company only supplies technology to insurance companies, it may be treated as an ordinary technology provider. However, where it solicits, sells, compares or distributes insurance products, it may require registration from IRDAI.

Foreign investment in insurance companies and insurance intermediaries is subject to the applicable FDI Policy and IRDAI conditions. Even where foreign investment is permitted under the automatic route, the company must comply with licensing, capital, governance and ownership requirements. The transaction should also be reviewed to determine whether prior regulatory approval is required due to a change in control or management.

Automatic Route for Foreign Investment

Under the automatic route, the foreign investor and Indian company are not ordinarily required to obtain prior approval from the Government of India before making the investment. However, the automatic route does not mean that the transaction is completely free from regulatory requirements. The company must still comply with the sectoral cap, pricing guidelines, investment instrument rules, Companies Act procedures and RBI reporting requirements.

The company may also need approval from a financial regulator where the investment results in a change in ownership, control or management. Therefore, automatic-route eligibility should not be treated as a complete approval for the entire transaction.

Government Approval Route

Prior government approval may be required where the proposed investment falls within a restricted sector, exceeds the automatic-route limit or relates to an unregulated financial activity. Approval may also be necessary where the beneficial owner of the investment is located in a country that shares a land border with India.

The application is generally submitted through the Foreign Investment Facilitation Portal and is examined by the relevant administrative ministry or department. The approval process may involve submission of the business plan, investor ownership structure, valuation report, source-of-funds details, transaction documents and beneficial ownership declarations.

Investment from Countries Sharing a Land Border with India

Foreign investment from an entity situated in a country sharing a land border with India is subject to the government approval route. This restriction also applies where the immediate investor is incorporated in another country but the ultimate beneficial owner belongs to or is situated in a land-border country. Accordingly, a FinTech company must examine the complete ownership chain of the foreign investor.

The review should cover holding companies, investment funds, general partners, trustees, investment managers and persons exercising ultimate control. Using an intermediary company incorporated in Singapore, the United States or another jurisdiction does not automatically remove the approval requirement where the ultimate beneficial ownership falls within the restricted category.

Choosing the Correct Foreign Investment Instrument

Foreign investment in an Indian company may be made through permitted equity instruments such as equity shares, compulsorily convertible preference shares and compulsorily convertible debentures. Equity shares provide ownership rights in the company. Compulsorily convertible preference shares may provide preferential rights relating to dividends and repayment while ultimately converting into equity shares.

Compulsorily convertible debentures initially resemble debt instruments but must compulsorily convert into equity within the agreed period. Optionally convertible or redeemable instruments may be treated as debt rather than foreign direct investment. Such instruments may fall under external commercial borrowing or another regulatory context. The company should therefore avoid selecting an investment instrument solely on the basis of commercial convenience. Its legal classification under FEMA must also be considered.

Pricing and Valuation Requirements

Foreign investment transactions must comply with FEMA pricing guidelines. When an Indian company issues securities to a foreign investor, the issue price should not be lower than the fair value determined under an internationally accepted valuation methodology. Where securities are transferred from a resident to a non-resident, the transfer price should generally not be lower than the prescribed fair value. Where securities are transferred from a non-resident to a resident, the transfer price should generally not exceed the prescribed fair value.

The valuation should be conducted by a qualified professional, such as a chartered accountant, merchant banker or registered valuer, depending on the transaction and applicable law. Valuation may also be required under the Companies Act and the Income-tax Act. Therefore, the company should ensure that the transaction satisfies all applicable valuation frameworks.

Assured Returns and Exit Rights

Foreign investors often seek commercial protections such as put options, liquidation preference, anti-dilution rights and exit guarantees. These rights must be drafted carefully because FEMA generally does not permit a foreign investor to receive an assured or guaranteed return. An investor may be given the right to exit after a specified period, but the exit price should be determined in accordance with the applicable pricing guidelines at the time of exit.

A clause guaranteeing a fixed internal rate of return or predetermined buyback price may be treated as non-compliant. Transaction documents should therefore be reviewed from both commercial and regulatory perspectives.

Pre-Investment Regulatory Due Diligence

Before completing the investment, the foreign investor should conduct detailed regulatory due diligence of the FinTech company. The due diligence should identify all licences required for the company’s activities and verify whether those licences are valid. It should also examine whether the company is undertaking any activity beyond the scope of its licence.

The investor should review regulatory correspondence, inspection reports, show-cause notices and pending applications. Any unresolved regulatory issue may affect the value of the company and the investor’s ability to complete the transaction. Where the proposed investment results in a change in ownership or control, the company should identify and obtain the required regulatory approvals before closing.

FEMA Due Diligence

The company’s historical foreign investment records should be reviewed before receiving a new investment. The review should cover earlier FC-GPR filings, FC-TRS filings, FLA returns, downstream investment reports and foreign investment approvals. It should also examine whether shares were allotted within the prescribed period, whether the correct amount of investment was reported and whether any foreign investor transfer remained unreported.

Historical non-compliance may delay the new investment because authorised dealer banks and investors usually ask for confirmation that previous foreign investment transactions were properly completed. Where a violation is identified, the company may need to pay a late submission fee or apply for compounding, depending on the nature of the contravention.

Corporate Due Diligence

Corporate due diligence examines whether the company has been properly incorporated and is maintaining the records required under the Companies Act. The investor should review the company’s memorandum and articles of association, capitalisation table, statutory registers, board minutes, shareholder resolutions and previous allotments.

The review should also confirm ownership of intellectual property, particularly where the company’s software was originally developed by founders, consultants or overseas affiliates. Founder employment agreements, employee stock options, related-party transactions, litigation and material commercial contracts should also be examined.

Data Protection and Cybersecurity Due Diligence

FinTech companies collect and process sensitive personal, financial and transaction data. Foreign investors should therefore review the company’s data governance and cybersecurity practices. The review should examine how the company obtains customer consent, what information it collects, how long it retains the data and whether the data is shared with third parties.

The investor should also examine cross-border data transfers, cloud-hosting arrangements, data localisation requirements, cybersecurity audits and previous data breaches. Weak data governance can create substantial regulatory and reputational risk, particularly for digital lending and payment companies.

Process for Receiving Foreign Investment

Step 1: Analyse the FinTech Business Model

The company should prepare a detailed note describing its products, services, customer categories, revenue sources, fund flow and regulatory relationships. This note should clearly explain whether the company handles customer funds, facilitates loans, makes financial decisions or only provides technology. A proper business-model note helps advisors, investors and authorised dealer banks determine the correct foreign investment route.

Step 2: Identify the Sectoral Cap and Entry Route

After classifying the activity, the company should determine the applicable foreign investment limit and whether the investment falls under the automatic or government approval route. Where multiple activities are carried out, each activity should be examined separately. The most restrictive applicable condition may influence the transaction structure.

Step 3: Verify the Investor and Beneficial Ownership

The company should collect the incorporation documents, ownership structure and ultimate beneficial ownership information of the foreign investor. Where the investor is an investment fund, the company should also examine the fund manager, general partner, trustees and controlling persons. This review helps determine whether prior government approval is required under land-border investment restrictions.

Step 4: Obtain Regulatory Approvals

The company should identify whether approval is required from the RBI, SEBI, IRDAI, the Government of India or another regulator. Applications should be submitted before completing the transaction where prior approval is mandatory. The company should not assume that the automatic FDI route removes the requirement for a change-in-control approval from the relevant financial regulator.

Step 5: Finalise the Investment Structure

The company and investor should decide whether the investment will be made through equity shares, compulsorily convertible preference shares, compulsorily convertible debentures or a combination of primary and secondary transactions. The selected structure should comply with FEMA, the Companies Act and applicable sectoral regulations.

Step 6: Obtain the Valuation Report

A valuation report should be obtained before issuing or transferring securities. The report should determine the fair value using an internationally accepted methodology and should be prepared by the appropriate qualified professional. The valuation date should be reasonably close to the transaction date.

Step 7: Execute the Transaction Documents

The company, founders and investors may enter into a term sheet, share subscription agreement, share purchase agreement and shareholders’ agreement. These documents describe the investment amount, securities, conditions precedent, representations, warranties, governance rights and exit provisions. The articles of association should also be amended to incorporate the enforceable shareholder rights.

Step 8: Receive the Investment Consideration

The investment amount should be received through a permitted banking channel in accordance with FEMA requirements. The company should coordinate with its authorised dealer bank and obtain the foreign inward remittance details and investor KYC confirmation. Proper documentation should be maintained to establish the source, purpose and receipt of funds.

Step 9: Allot the Securities

After receiving the investment amount and satisfying the required conditions, the board of directors should approve the allotment of securities. The company should file the applicable return of allotment with the Registrar of Companies, issue share certificates and update its register of members and other statutory records.

Step 10: File the Applicable RBI Forms

After allotment or transfer, the company or responsible party must submit the prescribed FEMA reporting form through the RBI FIRMS portal within the applicable timeline. The filing should be supported by the valuation report, company secretary certificate, foreign remittance proof, investor KYC and corporate approvals.

Form FC-GPR

Form FC-GPR is filed when an Indian company issues equity instruments to a person resident outside India. The form is generally required to be filed within 30 days from the date of issue of the securities. It includes details of the investor, investment amount, securities issued, valuation, sectoral cap and foreign ownership after the allotment. Delayed filing may result in late submission fees and regulatory queries.

Form FC-TRS

Form FC-TRS is used for reporting a transfer of equity instruments between a resident and a non-resident. It may apply where an existing shareholder sells shares to a foreign investor or a foreign investor transfers shares to an Indian resident. The form is generally required to be filed within 60 days from the date of transfer or receipt or remittance of consideration, whichever is earlier. Responsibility for filing depends on the direction of the transfer and the applicable reporting rules.

Foreign Liabilities and Assets Return

An Indian company that has outstanding foreign direct investment may be required to file the annual Foreign Liabilities and Assets Return. The return is generally due by 15 July each year and contains details of the company’s foreign liabilities, foreign assets, share capital and financial position. The requirement may apply even where no fresh foreign investment was received during the relevant year.

Form DI for Downstream Investment

Form DI is used to report downstream investment made by an Indian entity that has received foreign investment. Where the foreign-owned or foreign-controlled Indian company invests in another Indian entity, the downstream investment must comply with the sectoral conditions applicable to the investee entity. The investment is generally reported within 30 days from the date of allotment.

Downstream Investment by FinTech Companies

A foreign-funded FinTech company may establish or invest in subsidiaries carrying out lending, payments, software or other activities. Before making such an investment, the company must determine whether it is considered foreign-owned or foreign-controlled.

It must also examine the sectoral cap, entry route, pricing conditions and regulatory requirements applicable to the subsidiary. For example, a foreign-funded technology holding company cannot automatically invest in an NBFC subsidiary without considering the rules applicable to regulated financial services.

Common Foreign Investment Risks for FinTech Companies

One of the most common risks is incorrect classification of the company as a pure technology provider. Where the company actually undertakes lending, payments or investment advisory, such classification may lead to regulatory non-compliance. Another risk arises where the company handles customer funds without the required authorisation. Even temporary control over customer money may attract payment-system or financial-services regulations.

Delayed RBI reporting is also a frequent issue. Missing FC-GPR, FC-TRS or FLA filing deadlines can create difficulties during future fundraising or investor exits. FinTech companies may also fail to examine the ultimate beneficial ownership of the investor. This can become serious where the investment is connected to a land-border country. Unreported downstream investments, guaranteed return clauses and changes in control without regulatory approval are other major areas of concern.

Penalties of Foreign Investment Non-Compliance

Non-compliance with foreign investment regulations can delay the investment transaction and prevent the company from accessing funds when required. The RBI or authorised dealer bank may reject a filing or ask the company to submit additional explanations and supporting documents.

The company may also be required to pay a late submission fee or apply for compounding of the contravention. Serious violations can attract penalties under FEMA and may also affect the company’s sectoral licence. Unresolved foreign investment issues may reduce investor confidence, delay subsequent funding rounds and complicate mergers, acquisitions or exits.

Role of a Foreign Investment Advisor

A foreign investment advisor assists the company in understanding how its business model is treated under Indian foreign investment regulations. The advisor determines the applicable sectoral cap, entry route, beneficial ownership requirements and regulatory approvals. The advisor also helps structure the investment instrument, coordinate valuation, review transaction documents and complete Companies Act and RBI reporting.

Where historical violations exist, the advisor may assist with delayed reporting, late submission fee applications or compounding. For a FinTech company, the foreign investment advisor should work closely with the company’s legal counsel, chartered accountant, company secretary, authorised dealer bank and sector-specific regulatory professionals.

Conclusion

Foreign investment can play an important role in the growth of Indian FinTech companies by providing access to capital, advanced technology, international networks and global business expertise. However, accepting foreign investment involves several legal and regulatory requirements. A FinTech company may need to comply with FEMA, the FDI Policy, the Companies Act, RBI directions and sector-specific regulations issued by SEBI, IRDAI or other authorities. Therefore, the company should first identify its actual business activity and determine the applicable sectoral limit, entry route, regulatory licence and reporting obligations.

Before completing the investment, the company should conduct detailed legal and regulatory due diligence to identify past FEMA violations, licensing gaps, data protection concerns and beneficial ownership issues. Proper structuring, accurate documentation and timely regulatory reporting can help prevent penalties, approval delays and complications during future fundraising or investor exits. A well-planned foreign investment strategy also helps the FinTech company protect its regulatory position and build a strong foundation for sustainable business growth.

Frequently Asked Questions

Q1. Is 100% foreign investment permitted in every FinTech company?

Ans. No. The permitted foreign investment limit depends on the actual business activity of the company. Pure software companies may generally receive 100% foreign investment under the automatic route, while regulated or unregulated financial services may be subject to additional conditions.

Q2. Is FinTech a separate sector under the FDI Policy?

Ans. No. FinTech is not a separate sector for foreign investment purposes. The company is classified according to whether it undertakes software services, lending, payments, insurance, securities services or another financial activity.

Q3. Can a foreign investor invest in an NBFC?

Ans. Yes, foreign investment may generally be permitted in an RBI-regulated NBFC under the automatic route. However, RBI approval may still be required where the investment results in a substantial change in shareholding, ownership or control.

Q4. Does a payment gateway require RBI approval?

Ans. A payment gateway providing only technology services may be treated differently from a payment aggregator or payment system operator. The requirement for RBI authorisation depends on the actual fund flow and services performed by the company.

Q5. Can a foreign investor receive a guaranteed return?

Ans. A foreign investor cannot ordinarily be provided an assured or guaranteed return that is inconsistent with FEMA pricing rules. Exit rights may be provided, but the price at the time of exit must comply with the applicable regulatory framework.

Q6. What is the deadline for filing Form FC-GPR?

Ans. Form FC-GPR is generally filed within 30 days from the date on which the securities are issued to the foreign investor.

Q7. What is the deadline for filing Form FC-TRS?

Ans. Form FC-TRS is generally filed within 60 days from the date of transfer or receipt or remittance of consideration, whichever is earlier.

Q8. Is the FLA Return required every year?

Ans. A company with outstanding foreign direct investment may be required to file the FLA Return every year, even where no fresh investment was received during that year.

Q9. Is government approval required for investment from a land-border country?

Ans. Yes. Government approval may be required where the investor or the ultimate beneficial owner is situated in or is a citizen of a country sharing a land border with India.

Q10. Can an unregulated FinTech company receive foreign investment?

Ans. An unregulated or partially regulated financial services company may require prior government approval. The company should obtain a proper business-model and regulatory classification before accepting the investment.

CA Manish Mishra is the Co-Founder & CEO at GenZCFO. He is the most sought professional for providing virtual CFO services to startups and established businesses across diverse sectors, such as retail, manufacturing, food, and financial services with over 20 years of experience including strategic financial planning, regulatory compliance, fundraising and M&A.