FEMA · FDI Reporting · FEMA 20(R)/2017-RB · RBI FIRMS Portal
FEMA FC-GPR Filing — 30-Day Deadline from Allotment
Raised foreign investment or allotted securities to a non-resident investor? FC-GPR is the RBI reporting step that ties your FIRC, board allotment, valuation certificate, investor KYC, and FEMA sector eligibility into one FIRMS portal filing.
Form FC-GPR must be reported within 30 days from the date of allotment / issue of securities to the foreign investor under RBI's foreign investment reporting framework. Late reporting is usually regularised through RBI LSF under A.P. (DIR Series) Circular No. 16 dated 30 September 2022. Substantive contraventions can require compounding under Section 15 of FEMA, 1999.
Receive remittance
AD Bank issues FIRC / bank advice for each foreign remittance tranche.
Allot securities
Board resolution and allotment date trigger the FC-GPR 30-day clock.
File FC-GPR
Submit Single Master Form on RBI FIRMS with valuation, KYC, and CS certificate.
Track acknowledgement
AD Bank / RBI processing leads to acknowledgement and UIN update where applicable.
What HRA prepares
FIRMS filing without document drift
Our job is to make sure the bank trail, allotment records, valuation, investor documents, and FEMA reporting all tell the same story.
- FIRC review and reconciliation
- CS Certificate coordination
- Valuation certificate compliance check
- Investor KYC review
- FIRMS portal submission
- Acknowledgement receipt and UIN tracking
FC-GPR Filing Intake
No file upload here. We collect the filing facts first; FIRC, KYC, CS certificate, and valuation documents are reviewed separately.
FIRC / BRC details
You need one FIRC per remittance tranche. Multi-tranche rounds need multiple FIRCs.
FC-GPR FAQs
What is Form FC-GPR and when must it be filed?
Form FC-GPR is the mandatory RBI reporting form for foreign direct investment received by an Indian company through issue of equity instruments to a person resident outside India. It is filed through the Single Master Form on the RBI FIRMS portal. The filing is due within 30 days from the date of issue or allotment of the capital instruments, as prescribed in the RBI Master Direction on Foreign Investment in India and the RBI reporting framework. The 30-day clock starts from allotment, not merely from receipt of funds.
What is the penalty for late FC-GPR filing and can it be regularised?
Delayed FC-GPR reporting is generally regularised through Late Submission Fee (LSF) under RBI/2022-23/122, A.P. (DIR Series) Circular No. 16 dated 30 September 2022. For transactional reporting such as FC-GPR, the LSF formula is INR 7,500 plus 0.025 percent of the amount involved multiplied by the number of years of delay. If LSF is advised and not paid within 30 days, the advice becomes void. Substantive FEMA contraventions may still require compounding under Section 15 of FEMA, 1999.
What is the valuation certificate requirement for FC-GPR?
Under the FEMA foreign investment pricing framework, issue of equity instruments by an unlisted Indian company to a person resident outside India should not be below fair value determined using an internationally accepted pricing methodology on an arm length basis, certified by a SEBI-registered Merchant Banker or Chartered Accountant, as applicable. The RBI Master Direction on Foreign Investment also states that the valuation certificate for pricing guidelines must not be more than 90 days old as on the investment date.
What is the FLA return and does our company need to file it every year?
The Foreign Liabilities and Assets Annual Return is filed on FLAIR, the RBI Foreign Liabilities and Assets Information Reporting portal, not the FIRMS portal. It is generally due by 15 July each year for Indian resident entities with outstanding foreign liabilities or assets as at 31 March. It can be required even when there is no new FDI during the year, as long as the foreign investment position remains outstanding.
Are there sectors where FDI is prohibited or restricted?
Yes. The FEMA NDI framework and DPIIT FDI policy prescribe sectoral caps, entry routes, and prohibited sectors. RBI Master Direction on Foreign Investment states that foreign investment is permitted up to 100 percent under the automatic route for sectors not listed with caps or conditions and not prohibited, while the investee company is responsible for compliance with sectoral caps and conditions. Inventory-based e-commerce, for example, is not permitted for foreign investment under the cited RBI direction.
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