FC-GPR filing on RBI FIRMS portal — Step-by-step

When an Indian company issues equity shares, compulsorily convertible preference shares (CCPS), or compulsorily convertible debentures (CCDs) to a person resident outside India, it must report the transaction to the Reserve Bank of India (RBI) by filing Form FC-GPR through the FIRMS (Foreign Investment Reporting and Management System) portal.

Failure to file within the prescribed timeline may result in FEMA non-compliance, delays in future FDI transactions, and additional regulatory costs.

Let’s understand the complete filing process step by step. 🚀

What is FC-GPR?

FC-GPR (Foreign Currency–Gross Provisional Return) is the statutory form used by an Indian company to report the issue of eligible capital instruments to a non-resident investor under the Foreign Direct Investment (FDI) framework.

The filing is made online through the Single Master Form (SMF) available on the RBI FIRMS portal and is routed through the company’s Authorised Dealer (AD) Bank.

When is FC-GPR Applicable?

FC-GPR is required when an Indian company issues:

• Equity Shares
• Compulsorily Convertible Preference Shares (CCPS)
• Compulsorily Convertible Debentures (CCDs)

to:

• Foreign companies
• Foreign individuals
• Overseas investors
• Foreign venture capital investors

under the applicable FDI policy.

⏰ Due Date for FC-GPR Filing

The company must file Form FC-GPR within 30 days from the date of allotment of capital instruments, not from the date of receipt of funds.

Example

• Foreign remittance received: 10 April
• Shares allotted: 20 May
• FC-GPR due date: 19 June

Remember, shares are generally required to be allotted within the FEMA-prescribed timeline after receiving the inward remittance, subject to applicable regulations.

Prerequisites Before Filing

Before starting the FC-GPR filing, ensure you have:

• Foreign inward remittance received
• Shares allotted by the Board
• Valid Digital Signature Certificate (DSC)
• Business User registration on FIRMS
• Entity Master updated correctly
• AD Bank details available

The RBI advises companies to ensure Entity Master details are accurate before making any filing.

Documents Required

Keep the following documents ready:

• Board Resolution for allotment
• Foreign Inward Remittance Certificate (FIRC) / inward remittance evidence
• KYC report of the foreign investor from the AD Bank
• Valuation Certificate from a Chartered Accountant or SEBI-registered Merchant Banker, as applicable
• Declaration by the authorised representative
• Company Secretary Certificate (where applicable)
• Government approval, if the investment falls under the Government Route

The exact document requirements may vary depending on the transaction.

Step-by-Step FC-GPR Filing Process

Step 1️⃣ Register on the RBI FIRMS Portal

Visit the official FIRMS portal:

RBI FIRMS Portal

Create:

Business User

and ensure the company’s:

Entity Master

is properly mapped.

Step 2️⃣ Login to the FIRMS Portal

Sign in using your Business User credentials.

Navigate to:

Single Master Form (SMF)

Step 3️⃣ Select “Form FC-GPR”

From the Return Type dropdown:

Select FC-GPR

Click:

Add New Return

The company details such as CIN and PAN are generally auto-populated.

Step 4️⃣ Enter Company Details

Verify:

Company Name

CIN

🆔 PAN

Sector

NIC Code

Ensure these match the latest MCA records.

Step 5️⃣ Enter Investment Details

Provide details such as:

• Entry Route (Automatic/Government)
• Sectoral Cap
• Date of allotment
• Type of instrument
• Number of shares issued
• Face value
• Issue price
• Premium amount
• Total investment value

Step 6️⃣ Enter Foreign Investor Details

Provide:

• Investor Name
• Country of residence
• Address
• Constitution (Individual/Company)
• Percentage of shareholding
• Beneficial ownership details, where applicable

Step 7️⃣ Enter Remittance Details

Fill in:

Amount received

AD Bank details

Date of remittance

FIRC/reference details

Currency

Step 8️⃣ Upload Supporting Documents

Attach all required documents in the prescribed format.

Typical uploads include:

• Valuation Certificate
• Board Resolution
• KYC Report
• Declaration
• Government approval (if applicable)

Incomplete or incorrect attachments are a common reason for rejection.

Step 9️⃣ Verify & Submit

Review every field carefully.

Digitally sign the form using the authorised signatory’s DSC.

Submit the application.

Step 🔟 AD Bank Verification

After submission:

• The Authorised Dealer (AD) Bank reviews the filing.

The bank may:

Approve

or

• Raise queries and send it back for correction.

All filings are first examined by the AD Bank before further processing.

FC-GPR Filing Workflow

Foreign Investment Received

│

▼

Board Allots Shares

│

▼

Prepare Supporting Documents

│

▼

Login to FIRMS Portal

│

▼

Complete FC-GPR Form

│

▼

Upload Documents

│

▼

Submit with DSC

│

▼

AD Bank Verification

│

▼

Acknowledgement / Approval

Common Reasons for Rejection

• Incorrect Entity Master details
• Wrong allotment date
• Mismatch in valuation
• Missing KYC report
• Incorrect FIRC details
• Wrong sector or entry route
• Missing government approval (where required)

Reviewing the form thoroughly before submission can significantly reduce delays.

Consequences of Late Filing

Missing the FC-GPR filing deadline may result in:

• FEMA non-compliance
• Requirement to regularize the delay through the prescribed mechanism
• Delays in future FDI reporting and transactions

Timely compliance is therefore critical.

Best Practices

• Complete share allotment within the prescribed FEMA timeline
• Prepare valuation reports before filing
• Coordinate with your AD Bank early
• Verify Entity Master details
• Maintain complete FDI documentation
• File well before the due date

FC-GPR Compliance Checklist

• Foreign remittance received
• Shares allotted
• Board Resolution passed
• Valuation Certificate obtained
• KYC Report received
• Business User registration active
• Entity Master verified
• Documents uploaded
• DSC attached
• FC-GPR submitted within 30 days

Final Thoughts

FC-GPR is one of the most important post-investment compliances for companies receiving foreign investment in India.

A timely and accurate filing helps ensure:

FEMA compliance

Smooth foreign investment reporting

Efficient coordination with AD Banks

Strong corporate governance

Hassle-free future fundraising

Proper planning, accurate documentation, and early coordination with your advisors and AD Bank can help avoid unnecessary delays and regulatory issues.

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