Unlisted company overseas issuance of ADRs/GDRs allowed without domestic listing, subject to compliance and reporting conditions. Unlisted Indian companies are permitted to issue ADRs/GDRs and raise capital abroad without prior or simultaneous domestic listing for an initial two year period, subject to conditions: listing only in IOSCO/FATF compliant or SEBI partner jurisdictions; compliance with sectoral caps, entry routes, minimum capitalisation and FDI pricing norms; upfront determination of ADR/GDR-to-equity ratios and pricing under Schedule 1 of FEMA Notification No.20; adherence to downstream investment instructions; limited permitted uses of funds abroad; repatriation and parking requirements if funds are not used abroad; and specified FEMA reporting obligations.