India's New Remittance Forms 145, 146: Compliance Risk for Banks

India replaced its foreign remittance reporting system on April 1, 2025. The new Forms 145 and 146 now govern how individuals and businesses report payments to non-residents or foreign entities. The change is procedural, not substantive: the core tax-compliance obligation remains identical to the old Forms 15CA and 15CB. The new forms introduce a clearer declaration structure and a mandatory Chartered Accountant certificate for transactions above ₹5 lakh that carry tax implications.

For anyone sending money abroad – whether for investments, property, education, or business payments – the immediate risk is a blocked transfer if the wrong form is filed or the CA certificate is missing. Banks are likely to enforce the new documentation strictly, given the government's stated goal of monitoring foreign remittances for tax compliance.

The Replacement of Forms 15CA and 15CB

The Income-Tax Act, 2025 framework retired Form 15CA (declaration) and Form 15CB (CA certificate). Their replacements are:

Old Form	New Form	Purpose
15CA	Form 145	Declaration by the remitter before making a foreign payment
15CB	Form 146	CA certificate required for certain high-value or tax-liable transactions

The income tax department's website states: “Form 145 is a new form that replaces the old Form 15CA for sending money outside India. It needs to be filled by anyone who wants to make a foreign payment, and it must be submitted before the money is sent.”

The practical rule: if you would have filed 15CA before, you now file Form 145. If you would have needed a CA certificate under 15CB, you now need Form 146.

Form 145: The Declaration

Form 145 is the primary reporting document. It must be filed by the person making the foreign payment – the remitter. The form collects:

Remitter's details (PAN, name, address)
Recipient details (name, country, bank account)
Amount and currency of remittance
Purpose code from a fixed list (e.g., education, investment, business payment)
Tax liability declaration (whether tax is due and whether it has been paid)

The fixed purpose-code list is designed to reduce errors that were common under the old free-text field. The income tax department can now match remittances to tax returns more efficiently.

Prerequisites for Filing Form 145

The remitter must be a registered user of the e-Filing portal with a valid user ID and password.
If the transaction falls under Part C (the category requiring CA certification), the CA must have already filed Form 146 before the remitter can submit Form 145.
Form 145 can be filed online or offline on the Income Tax portal.

Form 146: When a CA Certificate Is Required

Form 146 is the CA certificate. It is not needed for every remittance. The trigger is a transaction “above the prescribed limit of ₹5 lakh with tax implications,” according to the official guidelines. If the remittance is below ₹5 lakh or has no tax liability, Form 146 is not required.

The CA must:

Be registered on the e-Filing portal with their membership number.
Possess a valid Digital Signature Certificate (DSC).
Be assigned the Form 146 by the taxpayer through the portal.

Sector Read-Through: Banks and Fintechs in the Remittance Chain

The read-through for the financial sector is straightforward: any institution that processes foreign remittances must update its compliance workflows. Banks are the primary gatekeepers – they are likely to reject transfers if the correct forms are not attached. Fintech platforms offering cross-border payments will need to integrate the new form requirements into their user interfaces or risk losing customers to delays.

Exposed Entities Generically

While the source does not name specific companies, the sector includes:

Public sector banks – handle large volumes of NRI remittances.

Private banks – dominant in outward remittance for education and investment.

Money transfer operators – must ensure their Indian partners comply.

Fintech platforms – increasingly offer cross-border payment APIs.

For these entities, the operational cost is low – the change is a form update, not a system overhaul. The risk is execution: if a bank's portal does not accept Form 145 correctly, remitters may switch to competitors that process faster.

Valuation and Earnings Impact

No direct earnings impact is expected from this regulatory change. The compliance cost is absorbed in existing tax-filing infrastructure. Banks with strong digital remittance platforms may gain market share if they offer seamless integration of the new forms. Banks with manual processes could see a temporary increase in customer complaints and transfer delays.

Execution Risk for Remitters

The most immediate risk is for individuals and small businesses that send money abroad infrequently. They may not be aware of the new forms and could submit the old 15CA/15CB, which will be rejected. The income tax department warns that “providing incorrect or incomplete documentation can lead to delay in transfers or attract additional scrutiny at the bank level.”

What Confirms the Setup

A spike in rejected remittance applications at major banks in the first quarter after the change.

Public statements from banks or the income tax department clarifying common errors.

A rise in CA fees for Form 146 certification as demand increases.

What Would Weaken the Thesis

If the income tax department allows a grace period for old forms, reducing immediate disruption.

If banks pre-fill Form 145 data from existing customer profiles, making the change invisible to users.

If the ₹5 lakh threshold is raised or the tax-implications clause is clarified to exclude most education and medical remittances.

Next Test: July-September Education Remittance Peak

The first real test will be the July-September quarter, when education-related remittances peak ahead of the academic year. If banks process these smoothly, the transition will be considered successful. If delays occur, the income tax department may issue clarifications or relax enforcement.

For traders and investors, the direct catalyst is minimal. The indirect effect is on NRI-focused banks and remittance fintechs – any operational hiccup could create a short-term trading opportunity if the stock price overreacts. The fundamental thesis for these stocks remains driven by interest rates and economic growth, not form numbers.

Bottom line for traders: this is a compliance update, not a sector catalyst. Watch for execution errors in the first peak season. Do not build a position around it.

Key insight: The regulatory change is procedural. The risk is execution, not policy. Monitor bank complaint volumes and remittance processing times in July-September before making any watchlist adjustments.