IMPACT – MEDIUM

What is the change? The Indian Consulate in San Francisco is no longer requiring personal bank statements for most business visa applications.

What does the change mean? While personal bank statements will not be mandatory for most applicants, other supporting documentation including documentation providing details of travel plans, accommodations and intended activities will still be required.

  • Implementation time frame: Immediate and ongoing.
  • Visas/permits affected: Business visas.
  • Who is affected: S. nationals applying for business visas at the Indian Consulate in San Francisco.
  • Impact on processing times: Applicants may save some time by not having to provide bank statements; however, they should be sure to plan for the time required to provide other supporting documentation.
  • Business impact: In most cases, business travelers will not have to obtain and provide personal bank statements before submitting applications.

Background: As BAL reported in July, the Indian Consulate in San Francisco has focused on ensuring that business visa applicants provide clear and comprehensive information about their travel, including information about flight plans, accommodations and intended activities. While many additional documents are still required, personal bank statements are no longer required from most applicants. The consulate may follow up with requests on a case-by-case basis, especially when officials determine that proof of sufficient financial means is required. The majority of business visa applicants, however, will not be required to provide personal bank statements.

BAL Analysis: The change is welcome news to business travelers. However, applicants should be sure to leave enough time when preparing their applications to gather all other supporting documentation.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL representative.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? India has expanded its e-Tourist visa program to nationals of 36 additional countries.

What does the change mean? The program primarily benefits tourists from designated countries. Business travelers are advised to obtain visas from an Indian consulate before travel, except for urgent and very narrowly tailored business trips.

  • Implementation time frame: The 36 countries will be added Aug. 15.
  • Visas/permits affected: e-Tourist visas.
  • Who is affected: Nationals of the countries listed below.
  • Impact on processing times: E-Tourist visas are issued online before travel  to eligible nationals, who are limited to two per year.
  • Business impact: Although the Indian government allows travelers on “casual business visits” to use e-Tourist visas, the definition is extremely limited and business travelers should not attempt to use e-Tourist visas unless they are unable to obtain a visa from a consulate.

Background: Nationals of the following countries will be eligible for e-Tourist visas as of Aug. 15.

Andorra Colombia Jamaica Netherlands Slovenia Taiwan
Argentina Cuba Malta Panama Spain Tanzania
Armenia East Timor Malaysia Peru Saint Lucia Turks and Caicos Islands
Aruba Guatemala Mongolia Poland St. Vincent and the Grenadines United Kingdom
Belgium Hungary Monaco Portugal Suriname Uruguay
Bolivia Ireland Mozambique Seychelles Sweden Venezuela

The complete list of eligible nationals can be found on the Indian government’s website.

BAL Analysis: Individuals traveling to India on business are reminded that because of the narrow definition of business travel, the wide discretion that border officials exercise and the high risk of being turned away at a point of entry, BAL does not recommend that business travelers use e-Tourist visas.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – HIGH

What is the change? The Indian Consulate in San Francisco has imposed extensive new requirements on U.S. travelers applying for business visas.

What does the change mean? Affected travelers are now required to provide six months of personal bank statements, hotel and flight itineraries, and an additional letter of support from their U.S. employer. The letter of support must state the precise nature of the traveler’s activities in India and list the name and company address of the individual who signed the required letter of invitation.

  • Implementation time frame: Immediate and ongoing.
  • Visas/permits affected: Business visas.
  • Who is affected: U.S. nationals applying for business visas.
  • Impact on processing times: There is no evidence that processing times themselves have been affected, but the new requirements may add significant time to the overall application process.
  • Business impact: The change adds significant additional documentation requirements for business travelers.

Background: Over the course of the past week, the Indian Consulate in San Francisco began requiring new document requirements for travelers seeking business visas. BAL will follow whether the requirements will be implemented at other consulates in the U.S.

A statement posted to the website of the Indian Consulate in San Francisco on July 9 does not provide a reason for the recent changes, but does say that the Indian Embassy and consulates “reserve the right to seek additional documentation at their discretion” from visa applicants. The statement also warns travelers not to book travel arrangements without first obtaining the relevant visa for their travel.

BAL Analysis: BAL has only seen the new requirements implemented in San Francisco thus far, but business travelers should consider preparing the additional documentation no matter which consulate they are using when applying for a business visa. While the additional requirements add to the time required to apply for a visa, delays resulting from a lack of proper documentation could be significant.

Employers should also be aware that while electronic tourist visas (formerly called visas on arrival) are available for very limited business activities, the safest route for travelers seeking to enter the country for business activities is to obtain a multi-year business visa before entering India.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL representative.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? India’s Ministry of Home Affairs is advising members of the Indian diaspora who have not already converted their Person of Indian Origin (PIO) cards to Overseas Citizen of India (OCI) cards to submit an “OCI in lieu of PIO” application in the jurisdiction of their residence by Sept. 30.

What does the change mean? While the government did reaffirm that filing for conversion is voluntary, the consequences of missing the Sept. 30 deadline are unclear and therefore PIO cardholders should consider applying now.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: PIO cards, OCI cards.
  • Who is affected: PIO cardholders who have not yet applied for an OCI card.
  • Business impact: Business travelers should be aware that the Ministry’s policies regarding PIO cards are shifting and may change with little or no notice; conversion to an OCI card is therefore advised to avoid interruption of travel plans.
  • Next steps: PIO cardholders are advised to submit their “OCI in lieu of PIO” applications at their earliest convenience and preferably before Sept. 30.

Background: When India decided to phase out PIO cards, the Ministry of Home Affairs said that PIO cards would automatically be recognized as OCI cards from Jan. 9, 2015 onward and that PIO cardholders could apply to convert their PIO cards to OCI cards on a voluntary basis.

A recent government notice now advises PIO card holders to apply online by Sept. 30 and indicates that, in the meantime, border officers and airlines are being instructed to honor either PIO cards or OCI cards. OCI cards are smart cards that will speed up immigration clearance at Indian borders.

The notice also indicates that applicants may apply at the Indian consular post or Foreigner Regional Registration Office having jurisdiction over their current residence. Previously, the Ministry said that applicants were required to return to the location where the PIO was issued.

BAL Analysis: The Ministry’s notice could signal that a mandatory rule is forthcoming. Therefore, PIO cardholders should apply now for the conversion to avoid delays in obtaining OCI cards, which could interrupt travel plans. Because of regional differences, applicants should check with their local office or consulate to confirm procedures. BAL is closely monitoring policy changes regarding PIO card validity and will provide advice as new polices are confirmed.

This alert has been provided by the BAL Global Practice group and our network provider located in India. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Canada and France are among 31 countries that will be added to India’s e-Tourist visa program, the country’s Ministry of Home Affairs announced this week.

What does the change mean? Nationals of 76 countries are now eligible for the program. While the expansion of the program eases travel to India for tourists, it is not recommended for business travelers.

  • Implementation time frame: Immediate.
  • Visas/permits affected: E-Tourist visas.
  • Who is affected: Nationals of 31 additional countries traveling to India for tourism.
  • Impact on processing times: Processing times for travelers from eligible countries will be improved significantly.
  • Business impact: The business impact is minimal. Although India technically allows “casual business” visits on e-Tourist visas, BAL does not recommend using the e-Tourist visa for business purposes except in extremely limited circumstances.

Background: India dramatically expanded its Tourist Visa on Arrival-Electronic Travel Authorization program, as it was previously known, in November, making it available to nationals of more than 40 countries. This week, The Indian government announced that it will extend the program to nationals of 31 more countries. Those countries are:

Anguilla The Dominican Republic Latvia
Antigua and Barbuda Ecuador Liechtenstein
The Bahamas El Salvador Lithuania
Barbados Estonia Macedonia
Belize France Montenegro
Bolivia Georgia Montserrat
Canada Grenada Nicaragua
Cayman Islands Haiti Paraguay
Chile Holy See (Vatican City) St. Kitts and Nevis
Costa Rica Honduras Seychelles
Dominica

Indian authorities say they would like to extend e-Tourist visa eligibility to nationals of 150 countries by March 31, 2016, the end of India’s financial year.

The e-Tourist visa requires travelers to apply online prior to travel; those who show up without electronic travel authorization will be turned away. In order to clear up confusion, the program was renamed “e-Tourist Visa” in April.

BAL Analysis: While the program makes tourist travel easier, only “casual business” visits are allowed. The definition of what constitutes “casual business” may be left to the interpretation of individual immigration officers. Because of the discretionary manner in which e-Tourist visas may be issued and the fact that eligible foreign nationals may only be issued two of the visas per year, BAL only recommends e-Tourist visas for business travelers who do not have enough time to obtain a traditional business visa and are traveling for a one-shot meeting or “look-see” visit.

This alert has been provided by the BAL Global Practice group and our network provider located in India. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The Embassy of India in the U.S. and U.K. are requiring holders of previously issued Person of Indian Origin cards to obtain an Overseas Citizen of India card.

What does the change mean? PIO card holders living abroad in the U.K., U.S. and other countries are advised to convert to OCI cards according to the regional deadlines set by the Indian embassies.

  • Implementation time frame: The conversion of PIO cards to OCI cards became mandatory April 8 in the U.K. and will become mandatory June 18 in the U.S.
  • Visas/permits affected: PIO and OCI cards.
  • Who is affected: PIO card holders.
  • Impact on processing times: OCI card requests take six to eight weeks in the U.K. and eight to 10 weeks in the U.S.
  • Business impact: Business travelers relying on PIO cards should be aware of rule changes to PIO cards by the Indian consular posts in their country and jurisdiction of residence.
  • Next steps: PIO card holders who obtained their PIO card in the U.K. or U.S. should submit an application for an OCI card as soon as possible.

Background: The PIO card was merged into the OCI card in January. Originally, the Indian government said that current PIO holders would not be required to convert to OCI cards, but could voluntarily submit their PIO card to an Indian embassy or local Foreigner Regional Registration Office (FRRO) to have their card endorsed with lifetime validity.

However, the Indian Embassy in the U.S. has announced through its consular services contractor that PIO card holders may apply for an “OCI in lieu of PIO” conversion on a voluntary basis until June 17 before conversion becomes mandatory June 18. Similarly, the Indian Embassy in the U.K. began requiring PIO holders to convert to OCI cards April 8.

As BAL reported last month, the FRRO in Mumbai is no longer endorsing PIO cards and is requiring all PIO card holders to obtain an OCI card by the end of June.

BAL Analysis: Given the varying interpretations of immigration rules by authorities in India and at consulates abroad, members of the Indian diaspora holding PIO cards should confirm local policies regarding maintaining their PIO/OCI status. Because the “OCI in lieu of PIO” conversion can only be completed by the same consular post or FRRO that issued the PIO card, those who have moved to another jurisdiction may have to apply for a new OCI card, which carries higher government fees than the conversion process.

This alert has been provided by the BAL Global Practice group and our network provider located in India. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The Foreigners Regional Registration Office in Mumbai has implemented new requirements for late registrations and visa extension applications.  

What does the change mean? A company representative must appear at the Mumbai FRRO with an apology letter when the foreign employee is late with the FRRO registration or visa extension.

  • Implementation timeframe: Immediate.
  • Visas/permits affected: Employment visas.
  • Who is affected: Foreign nationals submitting late FRRO registrations or visa extension applications.
  • Impact on processing times: One day delay in processing.
  • Business impact: Therule imposes an additional burden on businesses by requiring them to send a representative to the FRRO to support late applications and on foreign employees to return the following business day to receive their residence permit or visa.
  • Next steps: Companies with branches in Mumbai should be sure that foreign employees’ FRRO registrations and visa extension applications are completed on time to avoid the new requirements.

Background: The FRRO in Mumbai announced that, effective immediately, it is implementing new procedures intended to deter late FRRO registration and visa extension applications. If a foreign national does not register within the required 14 days or is late in submitting a visa extension application, the Indian employer company must send a representative to accompany the foreign employee to the FRRO and bring an apology letter that explains why the registration or extension application is late. The representative typically should be the same person who has signed the company’s letter of undertaking and other support documents. Also, foreign nationals submitting the late registration or extension application must return the next business day to pick up their resident permits or visas instead of receiving them on the same day, which is the usual practice in Mumbai.

BAL Analysis: Companies operating in Mumbai must take care that foreign employees’ FRRO registrations and visa extension applications are submitted on time. The implementation of the new requirement and process delay in Mumbai is a sign that Indian authorities are cracking down on late filings by foreign nationals and their Indian employers. With this in mind, companies should be aware that these policy changes will likely soon appear at FRROs in other cities. BAL is monitoring other locations in India for implementation of similar policies and will report on any additional regional changes.

This alert has been provided by the BAL Global Practice group and our network provider located in India. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The Foreigner Regional Registration Office in Mumbai is requiring holders of previously issued Persons of Indian Origin (PIO) cards to obtain an Overseas Citizen of India (OCI) card by the end of June.

What does the change mean? PIO card holders who report to the Mumbai registration office should convert to an OCI card as soon as possible.

  • Implementation timeframe: Ongoing.
  • Visas/permits affected: PIO and OCI cards.
  • Who is affected: PIO card holders.
  • Business impact: This requirement does not impact the ability of PIO card holders to work while the OCI application is in process.
  • Next steps: PIO card holders reporting to the registration office in Mumbai should apply for an OCI card as soon as possible and no later than June.

Background: When the Indian government announced the merger of the PIO and OCI card programs in January, it stated that current PIO card holders were not required to obtain an OCI card, but instead could submit the PIO card to the local Foreigner Regional Registration Office and obtain an endorsement stating that it has lifetime validity. However, the regional office in Mumbai recently posted a notice that it would no longer provide an endorsement on any PIO cards and that all PIO card holders should obtain an OCI card by the end of June.

BAL Analysis: Immigration regulations in India are frequently interpreted differently by the authorities in the various regions. PIO card holders who are either staying in India or planning to travel there should confirm local policies regarding maintaining their PIO/OCI status. BAL is following the policy changes since implementation of the merger of PIO and OCI cards and will report on any additional regional changes.

This alert has been provided by the BAL Global Practice group and our network provider located in India. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The High Commission of India in London has announced that it will require biometric data capture for visas and other consular services beginning in March.

What does the change mean? Anyone applying for Indian visas or other consular services in the U.K. will be required to book appointments online before submitting applications and appearing in person to have biometrics taken. Once the change is implemented, applicants showing up at visa centers without an appointment may be turned away.

  • Implementation timeframe: The changes will be implemented in March. Exact dates are not yet confirmed.
  • Visas/permits affected: Indian visas, passports, OCI cards and other consular services.
  • Who is affected: Anyone needing any of the above services.
  • Impact on processing times: Indian authorities are hoping that the online appointment system will save time in the application process. However, it is possible that applicants will experience delays as the program is implemented.
  • Next Steps: BAL will continue to monitor the rollout of the biometrics program and will provide updates accordingly.

Background: The changes are part of India’s Immigration, Visa and Foreigners’ Registration and Tracking (IVFRT) program. As part of the program, India will make biometric data collection (fingerprint data and facial imagery) mandatory for all visa applicants. Mandatory biometrics have already been implemented in Australia, Malaysia and the Netherlands, among other countries.

In the U.K., the program will be launched at 14 visa centers, including three in London, in March. Once the program is operating, walk-in appointments will not be accepted. Exceptions will be made for medical emergencies, however. Diplomatic and official passport holders traveling on official business are also exempt and should submit their applications directly at the High Commission of India in London or the Consulates General of India in Birmingham and Edinburgh.

BAL Analysis: Once the mandatory biometrics program is implemented, applicants will be required first to apply online and then appear in person, by appointment, at a visa center. Walk-ins may be turned away. BAL will provide more information about the rollout when dates can be confirmed. Contact your BAL representative if you have questions about the program.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – LOW

What is the change? India is no longer requiring foreigners to register their children under age 16 with the Foreigners Regional Registration Office.

What does the change mean? In addition to the registration exemption for children, either parent may conduct all visa-related services at the FRRO on behalf of children under the age of 16.

  • Implementation timeframe: Immediate.
  • Visas/permits affected: Registration.
  • Who is affected: Children under 16.
  • Business impact: The changes should speed up registration and other visa-related services that formerly required children to be present.

Background: Generally, all foreigners staying longer than 180 days in India must register in person within 14 days of arrival. According to a recent notice posted by the Bureau of Immigration, children under 16 are now exempt from registration. In addition, for other visa-related services such as visa extensions or exit permits, either parent may visit the FRRO on behalf of children under 16.

BAL Analysis: The new policy relieves foreign nationals of the inconvenience of registering minor children.

This alert has been provided by the BAL Global Practice group and our network provider located in India. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.