If you host in India, the compliance ground moved under you in the last eighteen months, and a lot of operators haven't noticed. The form you file for foreign guests has a new name and a wider scope, the central law behind it was rewritten entirely, and the state-level rules on top of it are getting more specific every season.
None of this is a reason to panic. It is a reason to fix your arrival process now, while the change is administrative, rather than after an inspection makes it urgent.
What already changed
The central law was replaced. The Immigration and Foreigners Act, 2025 came into force on 1 September 2025, replacing four laws that had governed foreign nationals in India since 1920. This wasn't a tweak — it was a rewrite of the whole framework.
Form C is now Form III. The form accommodation providers file when a foreign guest arrives is issued under Rule 17 of the Immigration and Foreigners Rules, 2025. Filing is still online, through the e-FRRO portal at indianfrro.gov.in, and the deadline is unchanged: within 24 hours of the guest's arrival.
OCI cardholders are now included. This is the change that catches experienced hosts. You must file for Overseas Citizen of India cardholders, even though OCI holders themselves are not required to register personally. A guest with an Indian name, Indian family and an OCI card does not look like a reporting obligation — and is one.
It was never only about hotels. The obligation covers homestays, short-term rentals, landlords and private individuals hosting a foreign national, whether or not money changes hands. Hosting a friend from abroad, free, is still a filing.
Penalties reported under the framework run to fines of up to ₹5,000 per foreign guest, potential criminal liability for the owner or manager, and licence consequences for repeat failures. Most hosts who get caught aren't evading anything — they filed late, or didn't realise a particular guest counted.
What's tightening on top of it
There is no single national short-term rental law in India. The central obligation sits on top of a state layer, and that layer is where the movement is:
- Goa revised the documents required for homestay registration and renewal by administrative order in January 2026.
- Kerala runs a defined homestay policy with registration through the state tourism department and property standards to meet.
- Maharashtra expects a municipal trade licence.
- Himachal Pradesh requires guest registration in tourist zones, with rules developing around Manali, Shimla and Dharamshala.
- Delhi may require guest registration with local police.
The pattern matters more than any single rule: requirements are becoming more specific and more enforced, not less. Things that were optional in 2024 are mandatory in 2026, and the direction of travel is obvious. If you operate across more than one state, you are complying with several regimes at once.
(Rules vary by state and change often — confirm current requirements with your state tourism department, and treat this as practical guidance rather than legal advice.)
Why the OTA booking doesn't help you
Here's the practical problem, and it's the reason good hosts still miss filings.
The platform doesn't give you the data. An OTA passes a guest name and a masked contact address. It does not pass a passport number, a visa type, a date of arrival in India, or a nationality you can rely on. Every field Form III asks for has to be collected by you, separately.
The clock starts at arrival, not at check-in tomorrow. A guest landing at 11pm on Saturday gives you until Sunday night. If your process is "the manager files these on Monday", you are late by design, every weekend.
You often don't know a guest is foreign until they arrive. Which means the filing obligation appears at the worst possible moment — after travel, at the door, when nobody wants to discuss documents.
Chasing documents over WhatsApp creates a second problem. You end up with passport images sitting in a chat app, backed up to somebody's phone and cloud account. That is sensitive personal data with its own obligations, stored in the least defensible place possible.
What to have in place
The fix is not a bigger reminder system. It's collecting identity at booking, structured, and letting the system route it.
Verify when the booking is confirmed. A guest still planning their trip will complete an ID check on their phone in two minutes. The same guest at midnight with luggage will not. You also learn days in advance if someone won't verify — which is information you can act on, rather than a crisis on arrival night.
Route domestic and foreign guests differently, automatically. A domestic guest is a straightforward registration. A foreign national or OCI cardholder starts a 24-hour clock. That decision should be made by the system at the point of collection, not by a person recalling the rule late at night.
Never hold the documents yourself. Use a verification provider that stores the document while your own systems keep only the outcome and masked metadata. In SympleHost that's the QID integration — QID is a digital identity platform built for exactly this, already used by Indian hotels and homestays for guest registration. The verification request goes out with the booking, the guest verifies on their phone, the status lands on the reservation, and the passport itself never enters our database. If your current setup can't make that claim, change it before it's tested.
Make status visible where arrivals are handled. Whoever manages check-in should see, on the booking, whether verification is complete — not have to remember to open a separate portal.
Keep your state paperwork current. Registration, renewals and trade licences differ by state and expire. Diarise renewals the way you'd diarise an insurance policy.
A checklist for Indian hosts
- Confirm your state's homestay or short-term rental registration is current, and note the renewal date.
- Know that foreign nationals and OCI cardholders both require Form III, filed within 24 hours, through e-FRRO.
- Move ID collection to booking confirmation, not arrival.
- Ensure passport images are not stored in your chat apps, your email, or your own booking system.
- Give arrivals staff a single place showing verification status per booking.
- Re-check the rules once a year — the 2025 Act won't be the last change.
Why now rather than later
Compliance is one of those problems that costs nothing until it costs a great deal. The reason to fix the arrival flow this quarter isn't that an inspector is coming; it's that the change is cheap while it's voluntary and expensive once it isn't. Hosts who moved ID collection to booking confirmation before the 2025 Act barely noticed the transition — the data they needed was already being collected, and the new form just asked for it in a different place.
India is also the market where this pays back fastest in guest experience terms. Arrivals are often late, journeys are long, and the last thing a guest wants after a domestic connection into Goa is a photocopier at reception. Doing the check three days earlier is both the compliant path and the better welcome.
Frequently asked questions
What is Form III in India? It is the successor to Form C — the form accommodation providers file to report a foreign guest's stay. It is issued under Rule 17 of the Immigration and Foreigners Rules, 2025 and filed through the e-FRRO portal within 24 hours of arrival. Since the Immigration and Foreigners Act, 2025 came into force on 1 September 2025 it also covers OCI cardholders.
Do Airbnb hosts in India have to file Form III? Yes, if the guest is a foreign national or OCI cardholder. The obligation attaches to the accommodation provider — hotels, homestays and short-term rentals alike — not to the booking platform, and applies whether or not the stay is paid.
Do I need to register my homestay with the state? In most states, yes, and the requirements differ. Kerala, Goa, Maharashtra and Himachal Pradesh each run their own regime, and several have revised their paperwork recently. Check with your state tourism department rather than assuming a national standard exists — there isn't one.
Can I just collect passport photos over WhatsApp? You can, and many hosts do, but it's the weakest option available: incomplete data, chased at the worst moment, and sensitive documents left in a chat backup. A verification flow sent with the booking collects better data earlier and keeps the documents out of your systems entirely.
What happens if I file late? Reported penalties include fines of up to ₹5,000 per foreign guest, possible criminal liability for the owner or manager, and licence consequences for repeat failures. The more common cost is quieter: a pattern of late filings is exactly what makes an inspection unpleasant.
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