Disclaimer: This article is general information only. It is not legal advice, it does not create an advocate-client relationship, and it is not an advertisement or solicitation.
Key takeaways
- Form III is the form earlier known as Form C. The duty to file it lies on the keeper of the accommodation, not on the guest.
- Arrival and departure of every foreign guest, including an Overseas Citizen of India (OCI) cardholder, must be reported within twenty-four hours.
- Records must be kept electronically for at least one year and shown on demand to the officers named in the rules.
- A hotel, homestay, hostel, rented room or hospital can all be covered. Private family homes are a grey area.
Contents
Anyone who rents a room or a bed to a foreign visitor in Kerala, from a resort owner in Munnar to a homestay host in Fort Kochi, should know about Form III. The old habit of collecting a passport copy and filing the paperwork later no longer fits the rules. This guide sets out what the Bureau of Immigration publishes about the form and where the practical doubts lie.
From Form C to Form III
Under the Immigration and Foreigners Act, 2025 and the rules made under it, the form hoteliers called the C-Form is now Form III. The Bureau of Immigration describes it as "Form III (earlier known as Form-C)". It is filed electronically through the designated online portal or mobile application, which is accessed through the e-FRRO site at indianfrro.gov.in.
One change deserves attention. The Bureau's published text says that every keeper of accommodation must require every foreigner, including an Overseas Citizen of India Cardholder, to furnish particulars. An OCI cardholder is still not asked to register personally with the FRRO, but the host must report the stay. A host who assumed OCI guests were exempt should revisit that assumption.
Who has to file
The rules define accommodation widely. It covers a boarding house, club, rest house, hostel, paying guest house, sarai, rented accommodation, home stay and tents, as well as premises of religious institutions, charitable trusts and other public or social organisations, furnished or unfurnished. Hospitals, nursing homes and medical institutions that provide lodging or sleeping facilities have a parallel duty, and must also report births to or deaths of foreigners within seven days.
Private homes are less clear. As reported, the Act is understood to treat residential premises of a non-commercial nature differently unless a local civil authority has directed otherwise, yet some FRRO notices have urged private hosts to file as well. A host in this position should check the position for the local area before relying on any exemption.
The twenty-four hour rule
The keeper must transmit the filled Form III electronically as soon as may be, but not beyond twenty-four hours after the foreigner arrives. The departure details must also be sent within twenty-four hours after the foreigner leaves. Weekly batch filing does not fit this wording.
Particulars and records
| Stage | Duty |
|---|---|
| On arrival | Require the guest to furnish the necessary particulars and sign. A thumb impression is accepted for a guest who cannot write. |
| Language | Record in English if able, otherwise in an Indian language, and explain the requirement if the guest does not understand English and asks. |
| On departure | Record the date and time of departure and the address the guest is proceeding to. |
| Retention | Keep the particulars electronically for at least one year. |
| Inspection | Make them available on demand to the Registration Officer, District Magistrate or a police officer not below the rank of Head Constable. |
Passport and visa images are personal data. Our note on a Kerala High Court ruling on the Data Protection Board explains why handling of identity documents is attracting attention. A property should limit who can open these records, avoid keeping scans in personal phones or chat applications, and check how the Digital Personal Data Protection Act, 2023 applies to it as its provisions come into effect.
Risks of not filing
The Bureau of Immigration states that hoteliers, educational institutions and hospitals are liable to penalties ranging from Rs 10,000 to Rs 3 lakh for each offence, as well as imprisonment, for violating the Act. The exact consequence depends on the provision and the facts, and some offences may be compounded. A pattern of late filing is the kind of thing that draws scrutiny at an inspection. Kerala businesses dealing with several regulators may also find our guide on export compliance in Kerala useful as an example of building a checklist.
Questions people ask
Does the foreign guest file Form III?
No. The duty is on the keeper of the accommodation, who files electronically on the designated portal or application. The guest must supply the particulars.
Do OCI cardholders need to register with the FRRO personally?
The personal registration exemption for OCI cardholders is understood to continue. The host, however, must report the stay through Form III.
How long must the records be kept?
The Bureau's published text requires the particulars to be kept electronically for at least one year and to be available for inspection on demand.
Questions on a specific matter depend on the facts, and advice should be taken before acting.