Form C Compliance: What Manufacturing Companies in India Must Know

Introduction

India’s manufacturing sector is experiencing a steady influx of foreign engineers, technicians, auditors, and project managers as global companies establish or expand their production footprint. These professionals often stay in factory-owned guesthouses, industrial township residences, or vendor-arranged accommodations during their assignments. While these setups are convenient for operational efficiency, a critical legal compliance is frequently overlooked: submission of Form C to the Bureau of Immigration within 24 hours of a foreign national’s check-in.

Whether it's an OEM facility in Pune or an electronics plant in Sriperumbudur, failure to file Form C can lead to avoidable immigration scrutiny, operational delays, and even legal penalties. This guide provides a comprehensive overview of Form C compliance, recent regulatory developments, best practices, and actionable steps for manufacturers.

Why Form C Matters in the Manufacturing Context

Unlike startups that rotate founders across cities, manufacturers often host foreign nationals at:

• Factory-owned or leased guesthouses near industrial plants
• Residential quarters in industrial zones or SEZs
• Hotels or apartments arranged through third-party vendors

The obligation to file Form C lies with the accommodation provider—this could be the company itself, a third-party facility manager, or a hotel. However, the employing company is ultimately responsible for ensuring compliance, especially when accommodations are arranged internally or through vendors.

Non-compliance is common because:

• Guesthouse caretakers are unaware of immigration rules
• Accommodation is arranged informally through local plant admin teams
• Multiple departments (Admin, HR, Projects) manage mobility without central oversight

Consequences of Missed Form C Filings

• Issues during visa extensions, re-entry permits, or FRRO renewals
• Compliance notices or delays during audits
• Legal liabilities for the foreigner and their employing entity under immigration laws

Penalties for Non-Compliance

Failure to comply with Form C requirements can result in:

• Fines and/or imprisonment for the accommodation provider under the Foreigners Act, 1946
• Blacklisting of the foreign national, leading to denial of future visas
• Reputational damage and increased scrutiny of the company’s future immigration applications

Recent Compliance Developments Manufacturers Should Know

1. Departure Reporting Now EnforcedForeigners Regional Registration Offices (FRROs) in regions like Chennai, Pune, and Gurugram now require Form C filing at both check-in and check-out. If a guest stays in a factory guesthouse for just two days and no departure Form C is filed, it’s a violation ( check 2025 update below).
2. Employer’s Liability is RealAlthough the obligation lies with the accommodation provider, the FRRO may hold the company employing the foreign national accountable in case of non-compliance. This means plant HR or Admin may need to justify lapses, and visa renewals can be denied due to missing Form C records.
3. Physical Form B Register RequirementIf your company operates its own guesthouse or staff quarters, you must maintain a physical Form B register (visitor logbook), in addition to submitting Form C online.
4. Digitalization of Form C FilingThe Bureau of Immigration has streamlined the online Form C portal, allowing for easier batch uploads and real-time tracking of submissions. Companies should ensure their admin teams are familiar with the latest digital processes and updates.

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.