Form C Compliance: For Hotels Hosting Expats in India

What is Form C & Why It Matters

Form C is an online reporting mechanism through which hotels, guesthouses, hospitals, and similar establishments must share details of foreign nationals staying on their premises.

• Purpose: Tracking foreign visitors, maintaining security, and updating immigration records.

• Deadline: Filing must be completed within 24 hours of arrival (or 12 hours for certain nationalities).

• Scope: Every guest requires an individual Form C — even in group bookings or for infants with passports.

Non-compliance is a direct violation of the Foreigners Act and attracts criminal penalties.

Who Must File & Exemptions

Obligated Entities:

• Hotels, guesthouses, serviced apartments, resorts, hostels, registered homestays, and medical institutions including hospitals.
• Applies to every foreign guest or inpatient, even for a single night.
• Each individual in group bookings or multiple patients must have an individual Form C.

Responsibility:

• The operator or management entity is responsible for filing Form C—even if operations are outsourced.
• Contracts with third-party operators or property managers must include compliance duties.

Exemptions:

• Nationals of Nepal and Bhutan.
• Holders of diplomatic or official passports.
• Other exemptions as per updated Government or FRRO notifications.

Information Required for Filing

At check-in or admission, verify and record:

• Full name (passport name)
• Nationality
• Passport number, date, and place of issue
• Visa type, number, and validity
• Date of arrival in India and port of entry
• Purpose of visit or treatment
• Expected duration of stay or treatment
• Local contact number and email
• Accommodation or ward/room details

Critical Deadlines You Cannot Miss

Guest's Country	File Within
Most countries	24 hours of check-in
Pakistan, China, Afghanistan, Bangladesh, Iran	12 hours of check-in
Nepal, Bhutan	No filing needed

Check-out or Discharge Filing: Filing upon check-out or discharge is recommended to maintain complete records but is not uniformly mandatory.

Missing these deadlines is where most property owners get into legal trouble. The government doesn't accept "I forgot" or "I didn't know" as valid excuses.

The Consequences Are Real and Serious

Here's where many property owners make a dangerous assumption. They think Form-C is just bureaucratic red tape that nobody really enforces. That's a costly mistake. The penalties for non-compliance include:

• Heavy fines that can run into thousands of rupees
• Criminal cases filed against property owners
• Jail time up to 5 years under the Foreigners Act
• Business license issues and potential closure

This isn't theoretical. In 2013, hotel staff in Pune were actually arrested for failing to file Form-C for a foreign patient. Since then, there have been numerous cases across India where Airbnb hosts and small hotel owners have faced police action for non-compliance. Some properties have even been blacklisted by tourism authorities.

The scary part is that most property owners only discover these consequences after they've already broken the law. By then, it's too late to claim ignorance or promise to do better next time.

Why Most Property Owners Struggle with Form-C

Common Challenges:

• Complex online portal that's difficult to navigate
• Document verification requirements that aren't obvious
• Different rules for different nationalities
• Technical glitches in government systems
• Language barriers in official documentation
• Keeping up with changing regulations

The Hidden Costs:

• Time spent figuring out the system
• Staff training requirements
• Mistakes that lead to penalties
• Guest complaints about delays during check-in

Many property owners don't realize how much time and stress this actually involves until they're deep into managing compliance themselves.

Form C Compliance Update 2025: Mandatory Departure Reporting Now Required

With the implementation of the Immigration and Foreigners Rules, 2025, notified by the Ministry of Home Affairs (MHA), the compliance requirements for Form C reporting in India have been expanded. Earlier, accommodation providers were responsible only for reporting the arrival and stay of foreign nationals. Now, the scope has been extended to include departure or checkout reporting as well, marking a significant regulatory enhancement in India’s immigration compliance framework.

This update underscores the government’s intent to create end‑to‑end tracking of foreign nationals through a centralised digital system managed by the Bureau of Immigration. By capturing accurate data from entry to exit, the new rules ensure that every visit is completely recorded. The move makes Form C compliance more comprehensive and technology-driven, helping authorities maintain an updated record of all foreign nationals staying in India.

What Has Changed Under the 2025 Rules?

Under the Immigration and Foreigners Rules, 2025, foreign nationals who are required to register in India must also ensure that their departure is reported to the concerned Registration Officer (FRRO/FRO) before they leave the country. The Rules are designed around a technology-enabled, online compliance system, using the Form C online portal and authorised digital platforms.

In practice, this means:

• Where the foreign national’s place of stay has been registered through Form C, the obligation to report applies both at arrival/check‑in and at departure/check‑out from that address and from India.
• The objective is to ensure that immigration records are properly closed, and there are no “open” or incomplete entries in the system when the foreigner exits India.

Role and Responsibilities of Hosts and Accommodation Providers

Hotels, guesthouses, serviced apartments, corporate housing providers, hospitals, educational institutions, and other entities hosting foreign nationals continue to play a central role in immigration compliance. While the primary obligation to report departure rests with the foreign national, hosts are expected to facilitate and support this process, particularly where Form C registration has been completed through their establishment.

Hosts should ensure that:

• Departure details are accurately updated in the registration records
• The actual or intended date of departure is correctly recorded
• Any required confirmation of exit or closure of registration is completed where applicable

By doing so, hosts help ensure that immigration records remain current, complete, and compliant with the 2025 Rules.

Why Departure Reporting Is a Critical Compliance Requirement

Historically, Form C compliance focused largely on reporting the arrival and stay of foreign nationals. The 2025 Rules adopt a more comprehensive compliance approach by explicitly recognising the importance of departure reporting as an integral part of immigration monitoring.

For hosts and establishments, failure to ensure proper departure reporting may result in:

• Incomplete or open immigration records
• Increased regulatory scrutiny or inspections
• Potential penalties or adverse compliance findings
• Complications during future visa applications or registrations involving the same foreign national or host entity

Timely and accurate departure reporting helps close the compliance loop, reducing legal exposure and demonstrating proactive adherence to evolving immigration regulations.

Here's How Expat Orbit can Help:

No More Technical Hassles
We take care of government portal navigation, system glitches, and downtime so your filings are never interrupted — even when official systems go offline.

Stay Fully Compliant
All filings are automatically submitted within required deadlines (24 hours in most countries, 12 hours in high-risk ones). Our team tracks regulation changes in real time and verifies every guest document to ensure accuracy.

Save Time and Costs
Skip the need for staff training on complex procedures. Check-ins move faster without compliance delays, and our dedicated support team is available whenever you need assistance.

Legal Peace of Mind
Every submission comes with a complete audit trail and instant confirmation receipts for your records. If authorities raise questions, our experts guide you through with confidence.

Conclusion

Form C compliance is a legal imperative for hotels and medical institutions alike. It safeguards your operations, assures regulatory adherence, and enhances the experience and safety of foreign guests and patients.

By knowing your obligations, training your teams, and leveraging technology, you can manage your compliance smoothly and avoid serious penalties.

At Expat Orbit, we work alongside property owners and institutions to simplify Form C filings, eliminate technical roadblocks, and provide audit-ready peace of mind. With our support, you can focus on running your business while staying fully compliant with immigration regulations.