Labor Compliance Calendar for Liaison Offices in India (FY 2026–27)
Labor and regulatory compliance calendar for liaison offices (LO) in India provide a structured framework of statutory obligations, covering labor laws, taxation, and regulatory filings. While LOs are restricted from undertaking commercial or revenue-generating activities under Reserve Bank of India (RBI) regulations, they are nevertheless treated as establishments employing personnel. As a result, they are required to comply with applicable labor and employment laws, alongside tax and foreign exchange regulations.
This calendar serves as an essential tool to ensure timely compliance, reduce regulatory risk, and maintain operational continuity.
Key legal framework governing LOs
The labor compliance requirements for LOs are governed by a combination of central and state-level legislation. Key statutes include the Code on Wages, 2019, and the Code on Social Security, 2020. In addition, the Shops and Establishments (S&E) Act, administered at the state level, plays a critical role in determining local compliance requirements.
It is important to note that shops and establishments compliance varies depending on the state of registration, requiring location-specific assessment.
Labor compliance requirements for liaison offices
Monthly compliance obligations
On a recurring basis, LOs must ensure timely deposit of statutory contributions and payroll-related compliance. This includes Employee Provident Fund (EPF) and Emloyee State Insurance (ESI) contributions where applicable, along with payroll processing and issuance of payslips. Tax Deducted at Source (TDS) on salaries, while governed by tax law, is operationally aligned with payroll and is typically tracked within the same compliance cycle.
TO KNOW MORE: TDS Rate Chart FY 2026-27: Domestic, Foreign, & Cross-Border Payments
Quarterly and half-yearly filings
At periodic intervals, LOs are required to file returns under labor laws and tax regulations. These include labor returns under the S&E framework, professional tax filings (where applicable), and statutory filings such as ESIC and Labor Welfare Fund (LWF) returns. TDS returns, such as Form 138 under the Income-tax Rules, 2026 (previously known as Form 24Q), are also filed quarterly, followed by issuance of TDS certificates to employees.
Annual compliance requirements
Annual compliance activities focus on statutory closure and validation. These include filing annual returns under the S&E Act, renewing registrations where necessary, maintaining and updating statutory registers, and issuing Form 130 (previously known as Form 16) to employees. These processes ensure that all employment-related records are accurately documented and compliant with regulatory requirements.
Event-based compliance triggers
In addition to periodic filings, certain obligations arise based on specific operational events. Employee onboarding requires execution of employment contracts and statutory registrations, while employee exits necessitate final settlements and gratuity payments where applicable. Changes in office address, employee strength, or closure of the LO must also be reported to relevant authorities within prescribed timelines.
Income tax compliance schedule for LOs
Although LOs do not generate income, they are responsible for TDS compliance and annual reporting. The following table outlines the key income tax-related obligations:
|
Month |
Due date |
Compliance/filing |
Frequency |
Remarks |
|
April 2026 |
April 30, 2026 |
Deposit TDS for March 2026 (non-govt. deductors) |
Monthly |
[CRITICAL] Extended date for March deductions only |
|
May 2026 |
May 7, 2026 |
Deposit TDS for April 2026 |
Monthly |
[REGULAR] 7th of following month — ongoing throughout year |
|
May 2026 |
May 31, 2026 |
TDS Return—Q4 FY 2025-26 (Forms 138/140/144) |
Quarterly |
[KEY] Form 144 for payments to non-residents — essential for LO |
|
June 2026 |
June 7, 2026 |
Deposit TDS for May 2026 |
Regular |
[REGULAR] 7th of following month — ongoing throughout year |
|
June 2026 |
June 15, 2026 |
Issue TDS Certificate — Form 131 for Q4 FY 2025-26 |
Quarterly |
[NOTE] Form 131 (salary) also due by June 15 |
|
July 2026 |
July 7, 2026 |
Deposit TDS for June 2026 |
Monthly |
[REGULAR] 7th of following month — ongoing throughout year |
|
July 2026 |
July 31, 2026 |
TDS Return — Q1 FY 2026-27 (Forms 138/140/144) |
Quarterly |
[KEY] Form 144 critical for LO — covers payments to non-residents HO staff |
|
August 2026 |
Aug 7, 2026 |
Deposit TDS for July 2026 |
Monthly |
[REGULAR] 7th of following month — ongoing throughout year |
|
August 2026 |
August 15, 2026 |
Issue TDS certificate — Form 131 for Q1 |
Quarterly |
[NOTE] Issue within 15 days of TDS return due date |
|
September 2026 |
September 7, 2026 |
Deposit TDS for August 2026 |
Monthly |
[REGULAR] 7th of following month —ongoing throughout year |
|
October 2026 |
October 7, 2026 |
Deposit TDS for September 2026 |
Monthly |
[REGULAR] 7th of following month — ongoing throughout year |
|
October 2026 |
October 31, 2026 |
TDS Return — Q2 FY 2026-27 (Forms 138/140/144) |
Quarterly |
– |
|
November 2026 |
November 7, 2026 |
Deposit TDS for Oct 2026 |
Monthly |
[REGULAR] 7th of following month — ongoing throughout year |
|
November 2026 |
November 15, 2026 |
Issue TDS Certificate — Form 131 for Q2 |
Quarterly |
– |
|
December 2026 |
December 7, 2026 |
Deposit TDS for Nov 2026 |
Monthly |
[REGULAR] 7th of following month — ongoing throughout year |
|
January 2027 |
January 7, 2027 |
Deposit TDS for Dec 2026 |
Monthly |
[REGULAR] 7th of following month — ongoing throughout year |
|
January 2027 |
January 31, 2027 |
TDS Return — Q3 FY 2026-27 (Forms 138/140/144) |
Quarterly |
[KEY] |
|
February 2027 |
February 7, 2026 |
Deposit TDS for Jan 2027 |
Monthly |
[REGULAR] 7th of following month — ongoing throughout year |
|
February 2027 |
February 15, 2027 |
Issue TDS Certificate — Form 131 for Q3 |
Quarterly |
– |
|
March 2027 |
March 7, 2027 |
Deposit TDS for Feb 2027 |
Monthly |
[REGULAR] 7th of following month — ongoing throughout year |
|
April 2027 |
April 30, 2027 |
Deposit TDS for March 2027 (non-govt. deductors) |
Monthly |
[CRITICAL] Extended date for March deductions only |
|
May 2027 |
May 31, 2027 |
TDS Return — Q4 FY 2026-27 (Forms 138/140/144) |
Quarterly |
[KEY] Covers Jan-Mar 2027 |
|
June 2027 |
June 15, 2027 |
Issue Form 131 for Q4 & Form 130 for salary (if any) |
Quarterly |
[NOTE] Issue wherever TDS has been deducted |
|
November 2027 |
November 30, 2027 |
File Form 162 — Annual statement for LO |
Annual |
[CRITICAL] Mandatory for every non-resident with LO in India; penalty INR 1000/day |
Ongoing regulatory obligations
LOs are required to fund all expenses through inward remittances from their head office (HO). Any changes in operational details, such as office address, authorized personnel, or scope of activities, must be reported to the RBI through the Authorized Dealer (AD) Bank within 30 days. Additionally, LO approvals are typically valid for three years, and renewal applications must be submitted at least two months prior to expiry.
LO compliance under FEMA
FEMA compliance ensures that LOs operate strictly within their permitted scope. The Annual Activity Certificate (AAC) remains the cornerstone of this framework.
|
Month |
Due date |
Compliance / filing |
Frequency |
Remarks |
|
July 2026 |
July 15, 2026 |
Annual Return on Foreign Liabilities & Assets (FLA) |
Annual |
[IF APPLICABLE] File only if FDI/ODI outstanding; most LOs are exempt |
|
September 2026 |
September 30, 2026 |
Submit Audited Financial Statements to AD Bank for FY 2025-26 |
Annual |
[CRITICAL] Accounts must be audited by statutory auditor |
|
September 2026 |
September 30, 2026 |
CA certificate — activities within permitted LO scope |
Annual |
[CRITICAL] Confirm no commercial/trading/industrial activity carried out |
|
September 2026 |
September 30, 2026 |
AAC — through AD Category-I Bank |
Annual |
[CRITICAL] Core LO filing; copy to DGIT (Intl. Taxation); non-filing can lead to LO cancellation |
|
As needed |
On occurrence |
Intimation to RBI—change in address / authorised person / activity |
Event-based |
[ACTION] Submit Letter through AD Bank within 30 days of change |
|
As needed |
2 months before expiry |
Renewal of LO registration—apply before validity expires |
As applicable |
[PLAN AHEAD] LO typically approved for 3 years; advisable to apply 2 months before expiry; AD Bank route |
|
March 2027 |
March 31, 2027 |
Ensure all expenses funded only through inward HO remittances |
Ongoing |
[ONGOING] LO cannot generate local income; all funds must come from parent HO abroad |
ROC filings for foreign companies under Companies Act, 2013
In addition to FEMA requirements, LOs must comply with filings under the Companies Act applicable to foreign entities:
|
Month |
Due date |
Compliance/filing |
Frequency |
Remarks |
|
March 2027 |
March 31, 2027 |
FC-2 — Update list of places of business in India (if changed) |
Annual |
[KEY] File within 30 days of FY end if any change in place of business |
|
May 2027 |
May 30, 2027 |
FC-4—Annual Return of a foreign company |
Annual |
[KEY] File Within 60 days from the end of the financial year. |
|
December 2027 |
December 31, 2027 |
FC-3 – Annual and the list of all principal places of business established in India by a foreign company |
Annual |
[KEY] File Within 60 days from the end of the financial year. |
Consequences of non-compliance
Failure to adhere to statutory requirements can result in financial penalties, regulatory restrictions, and operational challenges. This may include interest liabilities, limitations on employing expatriates, and complications in obtaining RBI approvals for renewal or closure. Specific non-compliance instances, such as failure to file Form 162 under the Income-tax Rules, 2026, or the AAC, may attract daily penalties or even cancellation of LO approval.
LO labor compliance under state-specific S&E Act
For LOs operating in India, labor compliance requirements are also influenced by state-level regulations, particularly the S&E Act. In states such as Maharashtra, the Act serves as a central framework governing workplace condition, employee records, working hours, leave policies, and annual reporting obligations.
Under the FY 2026-27 compliance calendar, LOs are required to file an annual return under the Maharashtra S&E Act (Form R), typically due by February-end. This consolidated return captures key operational details, including employee attendance, wage registers, and leave records, and is submitted to the state labor department.
Given the state-specific nature of the Act, compliance timelines, forms, and penalties may vary across jurisdictions. As such, maintaining an updated labor compliance calendar aligned with state-level S&E requirements is critical for ensuring operational continuity and regulatory adherence for Los.
Practical approach to compliance management for liaison offices in India
In practice, organizations adopt integrated approaches to manage compliance efficiently. This typically involves maintaining centralized compliance trackers or digital tools, outsourcing payroll and statutory compliance to specialized service providers, and aligning labor compliance processes with tax and FEMA requirements to ensure consistency and accuracy.
Conclusion
A comprehensive compliance calendar is critical for LOs operating in India. By systematically tracking labor, tax, and regulatory obligations, organizations can ensure timely compliance, mitigate risks, and maintain seamless operations within India’s regulatory framework.
Ensure Compliance with Liaison Office Requirements in FY 2026-27
With the implementation of four new labor codes and the Income-tax Act, 2025, liaison offices in India must align with evolving requirements, state-specific regulations, and reporting frameworks. Dezan Shira & Associates supports businesses with labor compliance calendars, regulatory filings, and advisory services to ensure seamless operations in India.
Connect with our India Tax Advisory Team → India@dezshira.com
Managing tax in India is critical for FDI companies to stay compliant with local regulations, GST requirements, and global standards such as IFRS, navigate complex filings, and apply correct tax treatments. A well-structured tax process helps to avoid penalties and stay 100% compliant.
About Us
India Briefing is one of five regional publications under the Asia Briefing brand. It is supported by Dezan Shira & Associates, a pan-Asia, multi-disciplinary professional services firm that assists foreign investors throughout Asia, including through offices in Delhi, Mumbai, and Bengaluru in India. Dezan Shira & Associates also maintains offices or has alliance partners assisting foreign investors in China, Hong Kong SAR, Vietnam, Indonesia, Singapore, Malaysia, Mongolia, Dubai (UAE), Japan, South Korea, Nepal, The Philippines, Sri Lanka, Thailand, Italy, Germany, Bangladesh, Australia, United States, and United Kingdom and Ireland.
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