LRS Remittance Refused? Form A2 & Purpose-Code Disputes

Quick answer: Ask the bank for the refusal reason in writing first. If a Form A2 purpose code is wrong, correct it and re-submit; the bank cannot process a remittance under a mismatched code. If the bank still refuses without a valid reason, file a written grievance with the authorised dealer (AD) bank, then escalate to the RBI Ombudsman after 30 days. If the bank alleges a FEMA breach, you can apply to RBI for compounding.

If you are short on time, jump to the step-by-step section and get the refusal reason in writing today. That one document drives every escalation that follows.

Why a wrong purpose code stalls a legitimate transfer

The Liberalised Remittance Scheme (LRS) lets a resident individual send money abroad through an authorised dealer (AD) bank for permitted purposes. The RBI says “all resident individuals, including minors, are allowed to freely remit up to USD 2,50,000 per financial year (April – March).”

Every outward remittance needs Form A2. This is the form where you declare why you are sending the money. The RBI requires that the remitter “furnish Form A-2 regarding the purpose of the remittance and declare that the funds belong to him and will not be used for purposes prohibited or regulated under the Scheme.”

On Form A2 the purpose is recorded as an RBI purpose code (an S-series code that classifies the reason for the transfer, such as education, maintenance of relatives, travel, or investment). The bank reports your remittance to the RBI under that code. If the code does not match your actual purpose, or your documents, the bank's system will reject or hold the transfer. A tuition payment filed under a maintenance code, or an investment filed under a gift code, is the most common reason a clean transfer gets stuck.

A refusal is not always a FEMA problem. Often it is a documentation or coding mismatch the bank wants fixed. So the first job is to find out exactly which it is.

Step-by-step: fix a refused LRS remittance

Step 1: Get the refusal reason in writing

Do not accept a verbal “it cannot be done”. Email the branch and your relationship manager and ask for the specific reason in writing: is it a purpose-code mismatch, a missing document, a limit issue, or a suspected FEMA breach? Keep the email; it is the basis for every later step.

Step 2: Correct the purpose code and Form A2 fields

Match the purpose code to what you are actually doing and to your supporting papers. Use the correct S-series code for your purpose - education versus maintenance of relatives are different codes with different documents. Check the current purpose-code list and Form A2 requirements with your AD bank or on the RBI site, because banks map codes to documents differently. Re-submit Form A2 with the corrected code and the matching proof (admission letter and fee invoice for education; relationship proof for maintenance; the relevant agreement for an investment).

Step 3: Escalate within the AD bank

If the code is right and the bank still refuses without a valid reason, file a formal written grievance. The RBI Integrated Ombudsman Scheme requires that “the complainant must first approach the concerned RE” (regulated entity, i.e. your bank). Use the bank's grievance-redressal channel, get a complaint reference number, and ask for a written reply within 30 days.

Step 4: Escalate to the RBI Ombudsman

If the bank does not resolve it, take it to the RBI Ombudsman. The RBI rule is clear: “If the RE does not respond within a period of 30 days after lodgment of the complaint or rejects the complaint wholly/partly or if the complainant is not satisfied with the response/resolution given by the RE, the complainant can lodge his complaint under the RB-IOS, 2021.” File online on the RBI CMS portal at https://cms.rbi.org.in. The complaint must reach the Ombudsman “not later than one year after receiving the reply of the RE or, in cases where no reply is received, not later than one year and 30 days after the date of the representation to the RE.”

Step 5: Apply to RBI for compounding if a breach is alleged

If the bank or the RBI says you actually contravened FEMA (for example, you crossed the annual limit), you can settle it through compounding instead of fighting a penalty. The RBI describes compounding as “the process of voluntarily admitting the contravention, pleading guilty and seeking redressal.” Any person who contravenes FEMA (with a narrow exception) “can apply for compounding to the Reserve Bank.” You submit the application with documents and a fee of “Rs. 10,000/- (Rupees Ten Thousand Only)” through the RBI PRAVAAH portal or physically.

Limit, TCS and which purpose codes attract scrutiny

The annual LRS ceiling is USD 2,50,000 per resident individual per financial year (April to March). Combined family remittances and prior transfers in the same year count toward this limit, so check your year-to-date usage before you remit.

Foreign remittances under LRS also attract tax collected at source (TCS) under the Income-tax Act. The rate depends on the purpose (education and medical treatment are treated more leniently than other purposes) and can change with each Union Budget. Do not rely on an old figure - check the current TCS rate and threshold for your purpose on the Income Tax / CBDT site or with your bank before you transfer, and remember TCS is adjustable against your tax liability when you file your return.

Purpose codes that draw the most scrutiny are large investment and capital-account transfers, transfers to newly added beneficiaries, round-tripping patterns, and any purpose where the documents do not match the code. Education and maintenance are routine, but only when the proof matches the code you declared.

Common mistakes

  • Treating a verbal refusal as final - always get the reason in writing.
  • Filing under the wrong S-series purpose code, then arguing instead of correcting it.
  • Submitting documents that do not match the declared purpose (a fee invoice under a gift code).
  • Ignoring the year-to-date LRS usage and crossing USD 2,50,000 across multiple transfers.
  • Missing the Ombudsman time limit after the bank's reply or non-reply.
  • Assuming every refusal is a FEMA breach - most are coding or document gaps.

Real-life example

Dr. Shrawan Kumar Pathak tried to remit tuition for his daughter's overseas university through his AD bank in March. The transfer was held. He emailed the branch and got the reason in writing: the Form A2 had been filed under a maintenance-of-relatives purpose code, not an education code, so the admission letter and fee invoice did not match the declared purpose. He re-submitted Form A2 with the correct education purpose code and the university's fee invoice. The remittance cleared within two working days. No FEMA issue existed - it was a purpose-code mismatch, fixed in one email and one corrected form.

Frequently asked questions

Education vs maintenance: which purpose code do I use?

Use the code that matches what the money is for. Tuition and study-related costs go under the education purpose code, supported by an admission letter and fee invoice. Money sent to support a relative living abroad goes under the maintenance-of-relatives code, supported by relationship proof. They are different codes with different documents. If you file education under a maintenance code, the bank will hold it. Check the exact current S-series code with your AD bank or on the RBI site, because the documentary requirements are mapped to the code.

What if I have exceeded the annual LRS limit?

The LRS ceiling is USD 2,50,000 per resident individual per financial year. If you have crossed it, the bank cannot process further remittances under LRS for that year, and a breach may be treated as a FEMA contravention. The practical route is to stop, document what happened, and consider applying to RBI for compounding - which lets you settle by admitting the contravention rather than facing a contested penalty.

How do I reply to a FEMA show-cause notice?

A show-cause notice asks you to explain an alleged contravention before any penalty. Reply in writing within the time given, attach your Form A2, bank correspondence, and proof of purpose, and explain the facts plainly. If a genuine breach occurred, compounding is usually the cleaner path: you apply to RBI, admit the contravention, and pay a settlement instead of fighting an adjudication. Consider professional help for the drafting, but the documents you gathered in Steps 1 to 2 are the core of any reply.

Can the bank report me to the authorities?

Yes. AD banks file regulatory reporting on outward remittances to the RBI as part of normal LRS compliance, and a genuine breach - such as crossing the annual limit or a prohibited-purpose transfer - can be flagged. This is exactly why you fix a purpose-code mismatch by correcting it, not by pushing the bank to process a transfer the code does not support. A clean, correctly coded transfer with matching documents is routine reporting, not a red flag.

What is the penalty if a FEMA breach is confirmed?

Under Section 13 of FEMA, a confirmed contravention can attract a penalty of up to three times the sum involved where the amount is quantifiable, or up to two lakh rupees where it is not, plus a continuing daily penalty in some cases. Compounding lets you settle instead, by admitting the contravention and paying a compounding amount. Check the current FEMA provisions and the RBI compounding directions before you respond.

Can I use an RTI to find out why my remittance was flagged?

The RTI Act applies to public authorities, and a private bank's internal decision is usually outside it. But where a public-sector bank or the RBI holds records about your case, you can file an RTI for the relevant correspondence or the policy applied. For a private AD bank, the bank's own grievance channel and the RBI Ombudsman are the effective routes, not RTI.

What to do in the next 30 minutes

  • Email the branch and your relationship manager asking for the refusal reason in writing.
  • Pull up your Form A2 and check the purpose code against what you are actually sending money for.
  • Gather the documents that match that purpose (admission letter, fee invoice, relationship proof, or agreement).
  • Note your year-to-date LRS usage so you know you are within USD 2,50,000.
  • If the bank stalls, draft a written grievance to its grievance-redressal officer and keep the reference number.

Next steps and escalation

  1. Correct and re-submit Form A2 with the right purpose code and matching documents.
  2. File the AD-bank grievance in writing and demand a reply within 30 days.
  3. Escalate to the RBI Ombudsman on https://cms.rbi.org.in if the bank does not resolve it in time.
  4. Prepare a compounding application through the RBI PRAVAAH portal if a FEMA breach is alleged.

For the broader strategy on using right-to-information and grievance tools against public authorities, read The RTI Playbook. You can also draft a grievance or RTI quickly with the AI RTI Drafter, build an escalation with the First Appeal Builder, and track your deadlines with the RTI Timeline Tracker.

Sources

Reader signal

Was this article useful?

Tap once if it helped you. These counters show other citizens which pages are worth reading.

- views