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India entry for global SaaS: What the May 2026 FDI notification changes

By Vishal Ranjan & Karan Malhotra · · India Entry

KAMRIT runs india entry engagements end to end with senior expert accountability and transparent fixed-fee pricing across India.

What changed

May 2026 FDI notification implications for global SaaS entering India. Entity choice, GST on cross-border services, GTM channel decisions. The notification was released earlier this month. KAMRIT clients across Delhi, Noida, Mumbai, Bengaluru, Hyderabad, and Chennai have started incorporating the change into the current quarter's compliance cycle.

Operational impact

The practical effect for most Indian businesses is in three places: documentation that needs to be maintained contemporaneously, filings that need to reflect the new position from a specific effective date, and audit working papers that need to capture the revised treatment. KAMRIT engagements over the last quarter have made this transition under monthly retainers without any client-side workload.

Edge cases to watch for

The notification has a handful of carve-outs that the underlying primary law leaves ambiguous. Where the position turns on the specific facts of the business, KAMRIT documents the position with a written memo and a contemporaneous reconciliation, so the file holds up under future scrutiny.

The compliance calendar going forward

The next due date that this change impacts falls in the current quarter. KAMRIT clients on monthly retainers receive a written close pack covering every regulator, every form, and every transaction. If your business is not on a retainer, KAMRIT also offers one-off remediation engagements priced as a fixed fee.

Talk to a senior expert

If this notification affects your business and you want a written view, send a quick brief to KAMRIT. A senior partner replies within one business day with a position memo and a fixed-fee quote if remediation is required. Browse the full India Entry services catalogue for related capabilities.

Author - Vishal Ranjan, Senior Partner
Co-Author - Karan Malhotra, Associate Partner, India Entry & FEMA

Vishal Ranjan

Senior Partner

Vishal Ranjan is Senior Partner at KAMRIT Financial Services LLP. He has 24 years of experience advising Indian and global enterprises on India entry, GTM strategy, M&A, and FEMA / RBI reporting. He has led over 200 India entry and GTM engagements across SaaS, manufacturing, healthcare, consumer goods, and exports.

vishal@vishalranjan.com

Karan Malhotra

Associate Partner, India Entry & FEMA

Karan is an Associate Partner leading the FEMA, FDI, and India entry desk at KAMRIT. He holds an LLM in International Business Law and a CS qualification with 10 years of experience in FDI advisory, FC-GPR, FC-TRS, ODI, ECB, and Press Note 3 analysis.

karan@kamrit.com

Frequently asked

Does this affect KAMRIT clients on a monthly retainer?

Yes, KAMRIT clients on a monthly compliance retainer see the relevant change baked into their next monthly close pack with no separate fee.

What if my situation is borderline?

Borderline cases are where KAMRIT adds the most value. We document the position contemporaneously and back it against the leading judicial precedents.

How quickly does KAMRIT respond?

One business day on standard enquiries. For active engagements with regulator or counterparty deadlines, out-of-hours support is included.

Ready to act on this?

A senior KAMRIT partner reviews every enquiry within one business day. Pricing is fixed-fee and transparent.

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