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Microlesson · 5-min read

FERA vs FEMA - Comparison of Key Features

# FERA vs FEMA: Key Distinctions

FEMA (1999) replaced FERA (1973). Understanding the philosophical shift between the two helps grasp why FEMA is structured the way it is.

## Comparison Table

BasisFERAFEMA
Residential StatusBased on citizenshipBased on stay in India
StrictnessForex transactions are prohibited unless permittedForex transactions are permitted unless restricted
Mens Rea (Guilty Mind)Presumption of existence of mens rea (accused presumed guilty)Mens rea is NOT presumed; prosecution must prove it
Compounding of OffencesNot allowedAll offences are compoundable

## Why This Matters

  • Philosophy shift: FERA was a control-oriented regulatory regime suited to a foreign-exchange-scarce economy. FEMA is a management-oriented regime aligned with liberalisation and reserve sufficiency.
  • Residential basis: A citizen of India living permanently abroad may NOT be PRI under FEMA, whereas under FERA citizenship alone could attract jurisdiction.
  • Burden of proof: Under FEMA, the Department must prove guilty intention; the assessee is not automatically guilty.
  • Compounding: Under FEMA, contraventions can be settled by paying a penalty without prolonged litigation.

## Memory Aid

Think FERA = Forbidden Unless Permitted and FEMA = Free Unless Restricted.

Worked example

### Example 1

Example 1: Mr. A, an Indian citizen, has been residing in Dubai for 10 years. Under FERA, he might be treated based on citizenship. Under FEMA, since his stay in India is less than 182 days in the preceding FY, he is a Person Resident Outside India (PROI).

### Example 2

Example 2: A forex transaction not specifically mentioned in FEMA rules — under FERA it would be presumed prohibited; under FEMA it is presumed permitted unless specifically restricted.

⚠️ Common exam mistakes

  • Confusing the burden of proof — under FEMA, mens rea is NOT presumed; the prosecution bears the burden.
  • Assuming citizenship determines residential status under FEMA (it is determined by stay in India, not citizenship).
  • Forgetting that all FEMA offences are compoundable — students confuse this with the Income Tax Act position.
Reference:
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