What is the LSF (Late Submission Fee) formula for delayed FC-GPR?

The Late Submission Fee (LSF) for delayed FC-GPR is calculated as: Rs 7,500 + (0.025% × transaction amount × number of days of delay). The LSF is capped at the total transaction amount. For example, for a Rs 1 crore investment delayed by 100 days: LSF = Rs 7,500 + (0.025% × Rs 1,00,00,000 × 100) = Rs 7,500 + Rs 2,50,000 = Rs 2,57,500. The LSF facility is available for delays up to 3 years from the due date under RBI Circular No. 16 dated September 30, 2022. Beyond 3 years, FEMA Compounding route applies.

What documents are required for FC-GPR filing?

Mandatory documents for FC-GPR: (1) FIRC from AD Bank, (2) KYC report of foreign investor from remitting bank, (3) Valuation Certificate from SEBI-registered Merchant Banker or practicing CA confirming share price is not less than FMV under DCF method, (4) Board Resolution approving allotment and authorising FC-GPR filing, (5) CS Certificate in RBI user manual format, (6) Declaration by the company, (7) PAS-3 acknowledgement from MCA. For Approval Route FDI, also include the Government approval letter.

What is the difference between FC-GPR and FC-TRS?

FC-GPR is filed when an Indian company issues new capital instruments to a non-resident investor, increasing the company's share capital. FC-TRS is filed when existing shares are transferred between a resident and a non-resident without new share issuance. FC-TRS must be filed within 60 days of execution of the transfer deed or date of payment, whichever is earlier. Both forms are filed on the RBI FIRMS portal under the Single Master Form system.

What is the annual compliance required after FC-GPR filing?

Companies that have received FDI must file the Annual Foreign Liabilities and Assets (FLA) Return by July 15 every year on the RBI's FLAIR portal (flair.rbi.org.in). The FLA Return reports the foreign investment position as on March 31. If accounts are unaudited by July 15, provisional figures must be submitted and revised by September 30. Failure to file FLA attracts an LSF of Rs 10,000 per year per company.

🌐 FEMA 20(R)/2017 · FIRMS Portal · SMF · FDI · RBI Compliance · AD Bank

FC-GPR Filing
with RBI FIRMS Portal —
FDI Reporting Guide 2025

Q: What is FC-GPR and when must it be filed?

Form FC-GPR (Foreign Currency Gross Provisional Return) is a mandatory RBI compliance filing under FEMA 20(R)/2017 that Indian companies must file when they allot capital instruments (equity shares, CCPS, CCD, or warrants) to a non-resident investor. It must be filed on the RBI FIRMS portal within 30 days from the date of allotment of shares — not the date funds were received. Filing is complete only when the Authorized Dealer (AD) Bank marks it as 'Acknowledged by RBI' within 5 working days.

Form FC-GPR (Foreign Currency – Gross Provisional Return) must be filed on the RBI FIRMS portal within 30 days of allotment of shares to a foreign investor. Missed deadlines attract Late Submission Fees (LSF) calculated as ₹7,500 + (0.025% × investment × days delayed). TAXAJ's FEMA team handles the complete FC-GPR compliance — from FIRC coordination to FIRMS portal filing.

30 Days

Filing Deadline

FIRMS SMF

RBI Portal

LSF Formula

Penalty

AD Bank

5-Day Review

📅 Book Free FEMA Consultation 💬 WhatsApp 🔄 FC-TRS Filing →

✦ FC-GPR — Key Facts

📋

What Is FC-GPR?

Foreign Currency – Gross Provisional Return for FDI inflow reporting

⏰

Deadline

Within 30 days of allotment of shares — NOT receipt of funds

🌐

Filing Portal

RBI FIRMS Portal (firms.rbi.org.in) — Single Master Form

🏦

AD Bank Role

Authorized Dealer Bank verifies within 5 working days

💸

LSF Formula

₹7,500 + 0.025% × amount × days · Capped at total investment

📊

Annual Follow-Up

FLA Return due 15 July every year for companies with FDI

🌐 CA + FEMA Expert Team⚡ Filed Within 7 Days🏦 AD Bank Coordination📋 FIRC + KYC Management⭐ 4.9★ Google Rating🇮🇳 Delhi · Bangalore · Goa · Bihar

What Is FC-GPR?

FC-GPR Filing with RBI — Complete FEMA Compliance Guide 2025

Form FC-GPR (Foreign Currency – Gross Provisional Return) is a mandatory compliance filing under the Foreign Exchange Management Act (FEMA), 1999 — specifically under FEMA 20(R)/2017 (Transfer or Issue of Securities to Persons Resident Outside India). When an Indian company receives Foreign Direct Investment (FDI) and allots equity shares, compulsorily convertible preference shares (CCPS), compulsorily convertible debentures (CCDs), or share warrants to a non-resident investor, it must report this transaction to the Reserve Bank of India (RBI) through the FIRMS (Foreign Investment Reporting and Management System) portal within 30 days of the date of allotment.

FC-GPR is a part of the Single Master Form (SMF) system introduced by the RBI on June 7, 2018 through A.P. (DIR Series) Circular No.30, which consolidated all foreign investment reporting into a unified online platform. The SMF integrates 9 different forms — including FC-GPR, FC-TRS, LLP-I, LLP-II, CN, ESOP, DI, DRR, and InVi — replacing the earlier dispersed reporting mechanism.

Critical Timing Clarification: The 30-day deadline for FC-GPR is calculated from the date of allotment of shares — NOT from the date the foreign remittance is received in the company's bank account. Many companies miss this distinction and file late. If shares are allotted on November 15, FC-GPR must be filed by December 15 — regardless of when the FIRC was issued or funds were credited.

When Is FC-GPR Required?

FC-GPR must be filed in the following scenarios:

Indian company receives foreign funds and allots equity shares to a non-resident investor
Indian company allots CCPS (Compulsorily Convertible Preference Shares) to a foreign investor
Indian company allots CCDs (Compulsorily Convertible Debentures) to a foreign investor
Shares are allotted to a foreign investor against capital goods, machinery, or pre-incorporation expenses (no FIRC in this case — alternative documents required)
Rights issue or bonus shares allotted to existing non-resident shareholders
ESOP exercise by a non-resident employee results in share allotment

What Is the FIRMS Portal?

The FIRMS (Foreign Investment Reporting and Management System) Portal at firms.rbi.org.in is the RBI's unified online platform for all foreign investment reporting in India. It handles two types of users: Entity Users (the Indian company's own employees, typically directors or CFOs) and Business Users (authorized professionals or consultants filing on behalf of the company, registered with approval from the company's AD Bank). The FIRMS portal integrates with the Entity Master Form (EMF) — which maintains the company's shareholding pattern and is updated after every FC-GPR acknowledgement.

Automatic Route vs Approval Route — Pre-FC-GPR Check

Before filing FC-GPR, verify the FDI route applicable to your sector. Under the Automatic Route, no prior government approval is needed — just the FC-GPR filing. Under the Approval Route, prior approval from the relevant ministry or FIPB (now processed through DPIIT) is required before FDI inflow. Sectors requiring Approval Route approval include defence above 74%, telecom, print media, multi-brand retail, and certain financial services. FC-GPR filed for Approval Route FDI must include the government approval letter as a mandatory attachment.

Filing Scenarios

Which FDI Scenario Applies to You? — Select Your Case

FC-GPR requirements vary by investment scenario. Select your situation for specific documents, timeline, and key compliance points.

🚀

Fresh Equity FDI — Standard FC-GPR Filing

Most common scenario · Angel / VC / PE / Foreign Parent investment · 30 days from allotment

The standard FC-GPR scenario: a foreign investor (angel, VC, PE fund, foreign parent company) transfers money to an Indian company, which then allots equity shares. The Indian company's board passes a share allotment resolution, PAS-3 is filed on MCA, and within 30 days of the board resolution date (not the money receipt date), FC-GPR must be filed on the FIRMS portal. The Authorized Dealer (AD) Bank that received the inward remittance must also verify and approve the filing within 5 working days. Filing is complete only when the AD Bank marks it as "Acknowledged by RBI."

Documents Required

FIRC (Foreign Inward Remittance Certificate) from AD Bank
KYC report of the foreign investor from the remitting bank
Valuation certificate from SEBI-registered Merchant Banker or CA (confirming share price ≥ FMV under DCF method)
Board resolution for allotment + authorisation to file FC-GPR
PAS-3 acknowledgement (MCA allotment filing)
Declaration by company (per RBI user manual format)
CS Certificate (Company Secretary confirmation)

Key Compliance Points

Shares must be allotted within 180 days of receipt of remittance
Share price must comply with pricing guidelines (min = FMV under DCF for unlisted cos)
FDI must be in a permitted sector (check sectoral cap in FDI Policy)
Automatic Route: no prior approval needed before filing FC-GPR
AD Bank must be the same bank that received the inward remittance
Exchange rate variance: ±0.5% or ₹10,000 (whichever lower) tolerance allowed

✅ TAXAJ handles: FIRC coordination with your AD Bank, KYC procurement, valuation certificate review, FIRMS portal Entity Master verification, FC-GPR filing, and AD Bank follow-up for acknowledgement.

💹

CCPS / CCD Allotment — Preferred / Convertible Instruments

Foreign investor gets CCPS or CCD instead of equity · 30 days from allotment

When a foreign investor (typically a PE/VC fund) invests in an Indian startup through Compulsorily Convertible Preference Shares (CCPS) or Compulsorily Convertible Debentures (CCDs), the FC-GPR must still be filed within 30 days of allotment. CCPS and CCDs are classified as FDI because they are compulsorily convertible into equity within a specified period. Important: Optionally Convertible instruments (OCPS / OCDs) are classified as External Commercial Borrowing (ECB), not FDI — they follow different reporting norms. Only compulsorily convertible instruments (converting within a maximum of 10 years) are FDI-eligible and require FC-GPR.

Additional Documents for CCPS/CCD

Term sheet / investment agreement showing conversion terms
Valuation certificate specifically for CCPS / CCD (may differ from equity valuation)
Board resolution specifying terms of CCPS/CCD issuance
Confirmation that instrument is compulsorily (not optionally) convertible
Articles of Association (AoA) clause permitting preference share/debenture issue

Key Watch-Points

Optionally convertible → ECB filing with RBI, not FC-GPR
Conversion of CCPS to equity later: file fresh FC-GPR at conversion date
Conversion price: must comply with pricing guidelines at conversion date
FDI cap: CCPS and CCD allotments count toward the sectoral FDI cap
Anti-dilution: any ratchet/anti-dilution clause must be FEMA-compliant

⚠️ Optionally Convertible ≠ FDI: Receiving foreign funds against OCD or OCPS is treated as External Commercial Borrowing (ECB) — not FDI. ECB has completely different reporting (Form ECB on FIRMS), interest payment restrictions, and end-use conditions. Misclassifying an optionally convertible instrument as FDI is a serious FEMA contravention.

⚙️

Non-Cash FDI — Shares Against Capital Goods / Pre-Incorporation Expenses

No FIRC available · Alternative evidence required · 30 days from allotment

A frequently overlooked scenario: FC-GPR is also required when shares are allotted to a foreign investor against non-cash consideration — such as capital goods brought in by the investor, machinery imports by the foreign parent, pre-incorporation expenses paid by a foreign investor on behalf of the Indian company, or technical know-how contributed by a non-resident. In these cases, there is no FIRC (since no money was remitted) — instead, alternative documents evidencing the underlying transaction must be attached to the FC-GPR filing.

Non-Cash FDI — Alternative Evidence

Customs Bill of Entry for capital goods / machinery imported
Invoices from foreign investor for goods or services provided
Pre-incorporation expense statements with receipts
Know-how / IP valuation certificate from SEBI-registered valuer
Agreement between company and investor specifying nature of contribution

Valuation Requirements

Valuation of non-cash contribution must be from SEBI-registered Merchant Banker or practicing CA
For capital goods: customs-assessed value acceptable in some cases
For know-how/IP: independent valuation certificate mandatory
Allotment price must be ≥ FMV of shares under DCF method

💡 Important: Non-cash FDI is perfectly valid under FEMA provided it falls within permitted FDI categories and adequate valuation is obtained. Companies receiving services from a foreign parent (in lieu of equity) must ensure proper documentation before allotment to avoid FC-GPR rejection at the AD Bank level.

📋

Rights Issue / Bonus Shares to Non-Resident Shareholders

Existing non-resident shareholder gets more shares · 30 days from allotment

When an Indian company issues Rights Shares or Bonus Shares to its existing shareholders (including non-residents), FC-GPR must be filed for the shares allotted to non-resident shareholders. For rights issues: the pricing must be offered to non-residents at a price that is not less than the price offered to residents. For bonus shares: no valuation certificate is required as no consideration is involved — a simple statement that the share price offered to non-residents equals the price offered to residents is sufficient. Filing is still required within 30 days of allotment to the non-resident shareholders.

Rights Issue — Documents

Rights offer letter (same price for residents and non-residents)
FIRC for rights subscription money from non-residents
KYC of the non-resident shareholder
Statement confirming rights price offered to non-residents ≥ resident price
Board resolution for rights allotment
No valuation certificate needed for rights issue

Bonus Issue — Key Points

No consideration paid by non-resident → no FIRC required
No valuation certificate required (bonus shares have zero cost)
Statement in lieu of valuation: bonus shares per existing shareholding proportion
FC-GPR still mandatory within 30 days of allotment
Pre and post-issue shareholding patterns must match correctly

✅ Renounced Rights: If a non-resident relinquishes their rights in favour of a resident (or vice versa), the resulting allotment must be tracked separately and may trigger FC-TRS requirements. Consult TAXAJ for complex rights issue structures involving mixed resident/non-resident allotments.

⏰

Late Filing — LSF Route (Beyond 30 Days)

Missed the 30-day deadline · LSF applies · Up to 3 years condonation available

If the 30-day filing deadline is missed, the company can still file FC-GPR through the Late Submission Fee (LSF) route under RBI Circular No. 16 (RBI/2022-23/122) dated September 30, 2022. The LSF facility is available for delayed filing up to 3 years from the due date. Beyond 3 years, the compounding route under FEMA applies (which is more expensive and requires RBI approval). The LSF is computed as: ₹7,500 + (0.025% × amount involved × number of days of delay), capped at the total transaction amount. LSF must be paid before the delayed FC-GPR is processed.

LSF Payment Process

Calculate LSF: ₹7,500 + 0.025% × amount × delay days
Pay LSF through the FIRMS portal (online payment)
Attach LSF payment receipt to the FC-GPR filing
File delayed FC-GPR with all normal documents
AD Bank reviews and approves — marks as "Acknowledged"

Beyond 3 Years — Compounding

Apply for compounding with RBI (Enforcement Dept)
RBI computes penalty: 0.5%–3% of contravention amount
Compounding order issued — pay and file for regularisation
TAXAJ handles compounding applications and RBI coordination
Typically takes 3–6 months for compounding orders

⚠️ Don't ignore late filings! An unreported FDI inflow is a continuing FEMA contravention. Each day of continued non-reporting adds to the contravention. TAXAJ has handled 100+ late FC-GPR filings — through LSF route (within 3 years) and compounding (beyond 3 years). Act now to limit penalty exposure.

Single Master Form (SMF)

All Forms Under the RBI SMF System — FC-GPR & Beyond

The FIRMS portal's Single Master Form consolidates 9 forms for all foreign investment reporting. Understanding which form applies to your transaction prevents misfiling and RBI rejections.

FC-GPR

Issue of Capital Instruments

Filed when Indian company allots equity, CCPS, CCD, or warrants to a non-resident. 30-day deadline from allotment.

Primary FDI Filing

FC-TRS

Transfer of Capital Instruments

Filed when shares of an Indian company transfer between a resident and non-resident (either direction). 60-day deadline from transfer deed or payment, whichever is earlier.

Share Transfer

LLP-I

FDI in LLPs

Filed when a foreign investor contributes capital to an Indian LLP. Equivalent of FC-GPR for LLPs. 30-day deadline.

LLP FDI

LLP-II

Disinvestment from LLP

Filed when a foreign investor transfers its LLP contribution to another person. Equivalent of FC-TRS for LLPs.

LLP Transfer

Convertible Notes (Startups)

Filed by DPIIT-recognised startups receiving foreign investment through Convertible Notes. Specific startup FDI instrument.

Startup CN

ESOP

Employee Stock Options to Non-Residents

Filed when Indian company issues ESOPs to non-resident employees who exercise them. Covers both listed and unlisted companies.

ESOP Filing

Downstream Investment

Filed when a company with foreign investment makes downstream investment in another Indian entity. Prevents round-tripping.

Downstream

DRR

Depository Receipt Return

Filed by companies whose shares are held in depositories as ADRs/GDRs. Tracks foreign holding through depository receipt programs.

ADR/GDR

InVi

Investment Vehicle

Filed by domestic investment vehicles (REITs, InvITs) receiving foreign investment. Specific to regulated investment structures.

REIT/InvIT

Filing Procedure

How to File FC-GPR on RBI FIRMS Portal — Complete Step-by-Step

TAXAJ handles Steps 1–7 in coordination with your AD Bank. You provide the allotment details and signed documents — we manage the portal filing.

Verify Sectoral Cap & FDI Route — Automatic vs Approval

Before accepting any foreign investment, verify that the proposed FDI complies with the Consolidated FDI Policy issued by DPIIT. Check the applicable sectoral cap (e.g., 100% automatic in IT, 74% automatic in defence, 100% with approval in some sectors). If Approval Route is applicable, obtain the government approval first — FC-GPR cannot be filed without the approval letter in such cases. TAXAJ reviews sectoral cap compliance and determines the FDI route as the first step in every FDI engagement.

📋 Critical first step · Avoid accepting funds before route confirmation

FDI Policy Compliance CheckSectoral Cap VerificationGovt Approval (if Approval Route)

Receive Foreign Remittance & Obtain FIRC from AD Bank

The foreign investor transfers funds to the Indian company's bank account (the AD Bank must be an Authorized Dealer Category-I bank — e.g., HDFC, ICICI, SBI, Kotak, Axis). Upon receipt, immediately request the FIRC (Foreign Inward Remittance Certificate) from the AD Bank — this is the primary evidence of money receipt for FC-GPR. Also obtain the KYC report of the foreign investor from the bank/intermediary that sent the funds. The KYC must be in a standardised format as per RBI requirements. Exchange rate at receipt date is noted for later comparison with allotment date rate.

📋 Request FIRC immediately after fund receipt — don't wait until allotment

FIRC from AD BankKYC of Foreign InvestorSWIFT Copy (optional)

Obtain Valuation Certificate — Price Compliance

For unlisted companies, shares can only be allotted at a price not less than the Fair Market Value (FMV) under the DCF (Discounted Cash Flow) method or any other internationally accepted method. The FMV must be certified by a SEBI-registered Merchant Banker or a practicing Chartered Accountant. The valuation certificate must be ideally not more than 90 days old at the time of filing FC-GPR. For listed companies, the floor price is the SEBI-prescribed formula (weighted average of last 26/52 weeks). This is a mandatory attachment — FC-GPR without a valid valuation certificate is rejected by the AD Bank.

📋 Valuation must comply with FEMA pricing guidelines · Merchant Banker or CA

Valuation Certificate (DCF / FMV)SEBI-registered MB / CANot older than 90 days

Pass Board Resolution & Allot Shares — File PAS-3 on MCA

The Board of Directors passes a resolution allotting shares to the foreign investor at the validated price. The share allotment resolution must specifically mention the foreign investor's name, country of residence, number of shares, price per share, and basis of valuation. After the Board resolution, file Form PAS-3 (Return of Allotment) on the MCA portal within 15 days of allotment. The 30-day FC-GPR deadline starts from this Board resolution date. Update the Register of Members and issue share certificates.

⏰ 30-day FC-GPR clock starts from allotment date · File PAS-3 within 15 days

Board Resolution (Allotment)PAS-3 (MCA — 15 days)Share CertificateMGT-14 (if required)

Register / Verify on FIRMS Portal — Entity Master & Business User

Before filing FC-GPR, verify that the Entity Master Form (EMF) is updated on the FIRMS portal with correct company details and shareholding pattern. If not registered, create an Entity User account. Register at least one Business User (BU) — the authorised person who will file on behalf of the company — with an authorisation letter from the company approved by the AD Bank. BU registration is processed by the AD Bank (not RBI directly) and typically takes 3–5 working days. If TAXAJ is filing as BU on your behalf, we handle our own BU registration with your company's authorisation letter.

📋 Entity Master must be updated · BU registration 3-5 days via AD Bank

FIRMS Entity Master (EMF)Business User RegistrationAD Bank Authorisation Letter

File FC-GPR on FIRMS Portal — Single Master Form

Log in to the FIRMS portal → Single Master Form → FC-GPR. The form is pre-populated with company details from the Entity Master. Fill in: Investment details (amount, type, currency), Issue details (date of allotment, type — equity/CCPS/CCD, price per share), Foreign investor details (name, country, entity type), Shareholding pattern pre and post allotment, FIRC details. Attach all documents in PDF format (max 1MB each): FIRC, KYC, Valuation Certificate, Board Resolution, CS Certificate, Declaration. Submit and note the Transaction Reference Number. The AD Bank receives an alert to review within 5 working days.

⏰ Within 30 days of allotment · All PDFs max 1MB · Note Transaction Ref No.

FC-GPR (FIRMS SMF)Transaction Reference No.All Documents (PDF ≤1MB)

AD Bank Review & RBI Acknowledgement

The Authorized Dealer (AD) Bank reviews the FC-GPR filing within 5 working days. If satisfied, the AD Bank marks the filing as "Acknowledged by RBI" — this is the final confirmation of a successful filing. If the AD Bank raises queries or rejects the filing, corrections must be made using the "Modification" feature and resubmitted. Upon acknowledgement, the Entity Master on FIRMS is automatically updated with the new shareholding pattern reflecting the foreign investor's stake. Download and preserve the acknowledgement as FEMA compliance proof. Follow-up: file the Annual FLA Return by July 15 every year.

📋 AD Bank acknowledges within 5 days · "Acknowledged by RBI" = filing complete

AD Bank AcknowledgementUpdated Entity MasterAnnual FLA Return (15 July)

LSF Calculator

FC-GPR Late Submission Fee (LSF) Calculator

Use this calculator to estimate your Late Submission Fee if you missed the 30-day FC-GPR deadline. LSF = ₹7,500 + (0.025% × investment amount × days delayed), capped at the investment amount.

💸 Calculate Your LSF Penalty

Investment Amount (₹)

Date of Share Allotment

Date of Filing (Today or Planned Filing Date)

⚠️ LSF Facility Available Only Up to 3 Years: Beyond 3 years from the due date, the LSF route is not available. Companies with very old unreported FDI must file through the FEMA Compounding Route — which involves applying to the RBI Enforcement Department and paying a compounding penalty ranging from 0.5% to 3% of the contravention amount. TAXAJ handles compounding applications for long-overdue FDI filings.

Penalties

FC-GPR Non-Compliance — LSF, Compounding & Consequences

Default	Timeline	Penalty / Fee	Authority	Route
Late Submission Fee (LSF) Route
Late FC-GPR (within 1 year of due date)	Up to 1 year	₹7,500 + 0.025% × amount × delay days	AD Bank via FIRMS	LSF — Self-filing
Late FC-GPR (1 to 3 years from due date)	1–3 years	Same formula — higher total due to more days	AD Bank via FIRMS	LSF — Self-filing
FEMA Compounding Route (Beyond 3 Years)
Unreported FDI beyond 3 years	> 3 years	Compounding: 0.5%–3% of contravention amount	RBI Enforcement Dept	Compounding application
Willful / repeated contravention	Ongoing	Up to 3× transaction amount under FEMA	RBI / ED	Prosecution possible
Annual Compliance — FLA Return
FLA Return not filed by 15 July	Annual	₹10,000 per year per company	RBI — FLAIR portal	LSF — ₹10K flat
LSF Formula Reference
LSF = ₹7,500 + (0.025% × transaction amount × number of days of delay)		Capped at the total transaction amount	Available up to 3 years from FC-GPR due date

FAQ

FC-GPR Filing — Frequently Asked Questions

Form FC-GPR (Foreign Currency – Gross Provisional Return) is a mandatory RBI compliance filing under FEMA 20(R)/2017 that Indian companies must file when they allot capital instruments (equity shares, CCPS, CCD, or warrants) to a non-resident investor. It must be filed on the RBI FIRMS portal within 30 days from the date of allotment of shares — not the date funds were received. For example, if shares are allotted on November 15, FC-GPR must be filed by December 15 regardless of when the FIRC was issued. Filing is complete only when the Authorized Dealer (AD) Bank marks it as "Acknowledged by RBI."

The mandatory documents for FC-GPR are: (1) FIRC (Foreign Inward Remittance Certificate) issued by the AD Bank, (2) KYC report of the foreign investor from the remitting bank, (3) Valuation Certificate from a SEBI-registered Merchant Banker or practicing CA showing share price ≥ FMV under DCF method, (4) Board Resolution approving allotment and authorising FC-GPR filing, (5) CS Certificate (Company Secretary's certificate as per RBI user manual format), (6) Declaration by the company in the RBI-prescribed format, (7) PAS-3 acknowledgement from MCA (allotment return). For Approval Route FDI, also include the Government approval letter.

The Late Submission Fee (LSF) for delayed FC-GPR is calculated as: ₹7,500 + (0.025% × transaction amount × number of days of delay). The LSF is capped at the total transaction amount. For example, for a ₹1 crore investment delayed by 100 days: LSF = ₹7,500 + (0.025% × ₹1,00,00,000 × 100) = ₹7,500 + ₹2,50,000 = ₹2,57,500. The LSF facility is available for delays up to 3 years from the due date, under RBI Circular No. 16 (September 30, 2022). Beyond 3 years, the FEMA Compounding route must be used — which is more expensive and requires RBI Enforcement Department approval.

Yes. FC-GPR is required even when no cash remittance is received — for example, when shares are allotted to a foreign investor against capital goods, machinery brought into India, pre-incorporation expenses paid by the investor, or technical know-how contributed. In these non-cash FDI cases, there is no FIRC (Foreign Inward Remittance Certificate) since no money was remitted. Instead, alternative documents are attached: customs Bill of Entry for machinery, invoices for goods/services, or valuation certificates for know-how/IP. The 30-day allotment deadline and all other FC-GPR requirements still apply.

FC-GPR is filed when an Indian company issues (allots) new capital instruments to a non-resident investor — the company's share capital increases. This covers fresh FDI investment where the company receives funds and allots new shares. FC-TRS (Foreign Currency – Transfer of Shares) is filed when existing shares are transferred between a resident and a non-resident — the company's share capital does not change. FC-TRS is filed within 60 days of execution of the transfer deed or date of payment, whichever is earlier. Both forms are filed on the FIRMS portal under the Single Master Form system.

After the initial FC-GPR filing, companies that have received FDI must file the Annual Foreign Liabilities and Assets (FLA) Return by July 15 every year on the RBI's FLAIR portal (flair.rbi.org.in). The FLA Return reports the position of foreign investment in the company as on March 31 of the preceding financial year. If accounts are unaudited by July 15, provisional figures must be submitted and revised by September 30. Failure to file FLA attracts an LSF of ₹10,000 per year per company. TAXAJ provides annual FLA Return filing as part of ongoing FEMA compliance management.

TAXAJ Services

FC-GPR & FDI Compliance — Service Packages

TAXAJ's FEMA + CA team handles the complete FDI compliance cycle — from sectoral cap check to FIRC coordination to FIRMS filing to FLA Return. Response within 2 hours.

FC-GPR Filing

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Single FC-GPR · Standard FDI inflow

✓FDI route & cap verification
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✓CS certificate + declarations
✓FIRMS portal filing
✓AD Bank follow-up for acknowledgement

Get Started →

Complete FDI & FEMA Compliance Services at TAXAJ

🔄

Received FDI? File FC-GPR
Within 30 Days or Pay LSF.

Sectoral cap check · FIRC coordination · Valuation · FIRMS portal filing · AD Bank follow-up · FLA Return. FEMA + CA team. Starting ₹7,999. Response within 2 hours.

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