FC-GPR filing for foreign investment

FC-GPR Filing for
Foreign Investment in India

30 Days, FIRMS Portal, Done Right the First Time

Form FC-GPR is the single most important RBI filing for any foreign-invested Indian company. Every share allotment to a non-resident triggers a 30-day clock to file FC-GPR through the FIRMS portal via the AD Category-I Bank. Filed correctly the first time, it takes a couple of hours and closes the loop on the FDI reporting cycle. Filed late or with errors, it triggers Late Submission Fees, AD-Bank rejection cycles, and in extreme cases FEMA compounding. This page walks through the timeline, documents, valuation requirement, and the AD-Bank workflow.

When FC-GPR Applies
  • Issue of equity shares to a non-resident investor.
  • Issue of Compulsorily Convertible Debentures (CCDs) or Compulsorily Convertible Preference Shares (CCPS).
  • Issue of warrants to non-resident (initial 25% upfront; balance on conversion within 18 months).
  • Issue of partly paid-up shares (initial 25% upfront; balance within 12 months).
  • Bonus issue or rights issue to existing non-resident shareholders.
  • Conversion of CCD / CCPS / convertible notes into equity.
Step-by-Step FC-GPR Filing Process
  1. Inward remittance arrives in AD Bank. AD Bank issues FIRC / e-FIRC with KYC details of the foreign remitter.
  2. Board meeting: board allots shares to the non-resident. Resolution recorded.
  3. Share certificates issued within 60 days of receipt of consideration; record in register of members.
  4. Valuation report obtained from SEBI-registered Merchant Banker or CA (if not already in hand from prior round).
  5. CS / CA certificate prepared confirming all FEMA conditions met — sectoral cap, route, downstream investment rules, NDI Rules.
  6. FIRMS portal entry: Entity User logs in, fills FC-GPR with all details, uploads supporting documents, submits to AD Bank.
  7. AD Bank reviews within their internal SLA; may seek clarifications; once satisfied, forwards to RBI.
  8. RBI acknowledgment received; transaction closed in the FDI compliance register.
Documents Checklist
  • FIRC / e-FIRC for the inward remittance.
  • KYC of foreign investor from the remitting overseas bank.
  • Board resolution allotting shares.
  • Form PAS-3 filed with MCA (return of allotment).
  • Valuation report (Merchant Banker / CA).
  • CS / CA certificate on FEMA compliance.
  • Copy of MoA / AoA of issuing company.
  • Sectoral approvals (RBI, DPIIT, sector regulator) if applicable.
Late Filing — What to Do
  • Delay up to 90 days: file with explanation; LSF computed and paid through AD Bank.
  • Delay 90 days to 3 years: LSF rises sharply; AD Bank may seek explanatory letter from the company.
  • Delay beyond 3 years: typically requires FEMA compounding rather than LSF; matter routed to RBI compounding officer.
  • Pre-2019 transactions: grandfathered LSF schemes have closed; legacy non-filings now follow standard LSF / compounding route.

We file FC-GPR end-to-end — from valuation coordination to FIRMS portal submission and AD Bank liaison. Engage us when you have an FDI inflow planned, or for retrospective filing of missed historical allotments.