Quick answer
What is FC GPR and when must it be filed?
FC GPR (Foreign Currency Gross Provisional Return) is the report an Indian company files when it issues equity instruments to a person resident outside India as foreign direct investment. Under the FEMA reporting regulations it is due not later than thirty days from the date of issue, through the authorised dealer bank on RBI's FIRMS portal.
- Due within 30 days of the issue of shares
- Filed on FIRMS, verified by your AD bank
- Needs a fair value certificate from a CA or SEBI merchant banker
- Late filing can be regularised with a late submission fee
What is FC GPR filing under FEMA?
FC GPR filing is the reporting of a fresh issue of equity shares, compulsorily convertible preference shares, debentures or similar equity instruments by an Indian company to a non-resident investor. It tells RBI who invested, how much, at what price and under which sector rules, so the investment is recorded as FDI.
The duty sits in Regulation 4(1) of the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019, notification FEMA 395/2019-RB, shown on RBI's site as amended up to 13 June 2026. The same regulation says reporting is made through or by an authorised dealer (AD) bank unless the rules say otherwise.
Common Delhi cases: a start-up raising a seed round from a US or Singapore fund, a subsidiary of a foreign parent receiving share capital, or an NRI founder putting money into a company on a repatriable basis.
What is the FDI reporting deadline for each form?
The FDI reporting deadline depends on the event: 30 days from the issue of shares for FC-GPR, 60 days for FC-TRS on a transfer, 30 days from receipt of consideration for LLP(I), and 15 July every year for the FLA return. All come from the same RBI reporting regulations.
| Form | Event | Time limit | Who files |
|---|---|---|---|
| FC-GPR | Issue of equity instruments to a non-resident as FDI | Not later than 30 days from the date of issue | Indian company |
| FC-TRS | Transfer of equity instruments between resident and non-resident | Within 60 days of transfer or receipt/remittance of funds, whichever is earlier | Resident transferor or transferee (non-resident in some non-repatriable cases) |
| LLP(I) | LLP receives capital contribution or acquires profit shares from a non-resident | Within 30 days from receipt of consideration | LLP |
| LLP(II) | Disinvestment or transfer of capital contribution in an LLP | Within 60 days from receipt of funds | LLP |
| ESOP | Issue of employee stock options to non-resident employees | Within 30 days from the date of issue | Indian company |
| FLA | Annual return on foreign liabilities and assets | On or before 15 July each year | Every Indian company or LLP with FDI |
Source: Regulation 4 of FEMA 395/2019-RB on rbi.org.in, checked October 2026.
Need help with FC-GPR filing? Talk to a chartered accountant in Delhi today. First call is free.
What documents are needed for FC GPR?
For FC GPR you need the bank's foreign inward remittance certificate and KYC report on the investor, the board or shareholder resolution for allotment, a fair value certificate on pricing, a company secretary certificate on compliance and the share allotment details. Your AD bank may ask for more.
| Document | Issued by | Purpose |
|---|---|---|
| Foreign Inward Remittance Certificate (FIRC) | Your AD bank | Proves the money came in through banking channels |
| KYC report on the non-resident investor | Remitting or AD bank | Identifies the investor |
| Board resolution for allotment (and shareholder resolution where needed) | Company | Date of issue starts the 30-day clock |
| Valuation certificate on fair value (pricing) | Chartered accountant or SEBI-registered merchant banker | Shows the issue price is not below fair value |
| Company secretary certificate | Practising company secretary | Confirms compliance with the Companies Act and FEMA conditions |
| Declaration by authorised representative | Company | Sector cap, route and other declarations |
| Share subscription agreement, MoA and AoA (if asked) | Company | Supports terms and authorised capital |
| Return of allotment (PAS-3) filed with ROC Delhi | Company | Matches the allotment reported to RBI |
Compiled from practitioner guides such as this FC-GPR guide (secondary). Confirm the list with your AD bank.
What is the capital contribution certificate and the pricing rule?
The pricing certificate, often called a valuation or capital contribution certificate, confirms that shares were issued to the foreign investor at not less than fair value worked out by an internationally accepted pricing method. For an unlisted company it is issued by a chartered accountant or a SEBI-registered merchant banker.
The pricing rule sits in rule 21 of the FEMA (Non-Debt Instruments) Rules 2019. Secondary summaries also list a practising cost accountant as a permitted valuer, which you should confirm before relying on it. For an LLP, the capital contribution from a non-resident follows similar fair value principles and is reported in Form LLP(I).
The valuation certificate is reserved professional work. A chartered accountant signs it with a UDIN. Our valuation certificate page explains how to check a valuer's credentials, and the CA certificate guide covers UDIN checks.
How do you file FC GPR on the FIRMS portal: step by step
Filing happens on RBI's FIRMS portal (firms.rbi.org.in) under the Single Master Form. The company registers a business user, makes sure its Entity Master is up to date, fills the FC GPR form, uploads documents and submits. The AD bank checks it and forwards it to RBI.
- 1
Receive funds and allot
Funds arrive through banking channels into the company's account. Allot shares within the time allowed after receipt and record the allotment date.
- 2
Collect bank papers
Get the FIRC and KYC report from your AD bank for each remittance.
- 3
Get the pricing certificate
A chartered accountant or SEBI-registered merchant banker certifies fair value as on a date close to the issue.
- 4
Check Entity Master and user access
The company's Entity Master on FIRMS must show current foreign investment details. A business user for the company is created and approved.
- 5
Fill and submit FC-GPR
Enter investor, instrument, price, sector and route details exactly as in the documents, attach the PDFs and submit.
- 6
AD bank review
The bank verifies the form. It may approve, ask for resubmission or reject. Mismatches with the FIRC or KYC are the usual reason for queries.
- 7
RBI acknowledgement
Once approved, the form is taken on record. Keep the acknowledgement with your secretarial records.
What is the late submission fee for FC GPR?
If FC GPR is filed late, you can regularise the delay by paying a late submission fee (LSF) of ₹7,500 plus 0.025% of the amount involved for each year of delay. RBI caps it at the amount involved, and the LSF route is open for up to three years from the due date.
| Item | RBI rule |
|---|---|
| Formula | ₹7,500 + (0.025% × A × n) |
| A | Amount involved in the delayed reporting |
| n | Years of delay, rounded up to the nearest month and expressed up to 2 decimals |
| Maximum | 100% of A, rounded up to the nearest hundred |
| Time limit for LSF | Up to three years from the due date of reporting |
| Delay beyond three years | Not covered by LSF; compounding route applies |
Source: RBI circular RBI/2022-23/122 dated 30 September 2022, checked October 2026.
What is the Entity Master and is ARF still needed?
The Entity Master is the company's master record of foreign investment on FIRMS, and it must be current before any Single Master Form filing. The old Advance Reporting Form (ARF) for inward remittances was dropped when the Single Master Form started, and its details now sit inside FC GPR.
RBI introduced the Entity Master and Single Master Form through A.P. (DIR Series) Circular 30 of 7 June 2018, and the Single Master Form went live on 1 September 2018. Practitioner summaries state that only the entity user can update the Entity Master. If your company received foreign investment before 2018 and never completed the Entity Master, sort that out before filing a new FC GPR.
When is FC-TRS filed instead of FC GPR?
FC-TRS is filed when existing shares change hands between a resident and a non-resident, for example an NRI buying shares from an Indian founder. FC GPR is only for fresh issues by the company. The FC-TRS deadline is 60 days from transfer or receipt of funds, whichever is earlier.
The reporting duty for FC-TRS falls on the resident transferor or transferee, not the company. Pricing rules also apply in the other direction: a non-resident selling to a resident generally cannot be paid more than fair value. Founders selling secondary shares to a foreign fund should line up the valuation before signing.
How can CA in Delhi help with FC GPR filing?
FC GPR filing is not reserved for chartered accountants, so the listed firms can handle it. Greenwolf Advisors works on cross-border structuring, entity setup and regulatory filings, which covers FDI reporting, and you get a fixed quote before work starts.
Greenwolf Advisors is an advisory firm, not a CA firm. Where a pricing certificate is required, it is issued separately by a chartered accountant or SEBI-registered merchant banker you engage. Founders setting up the Indian entity first can read our private limited company registration page, and annual filings after the round are covered under ROC compliance. Overseas founders and NRIs can also see our NRI tax services page. Browse every listed firm on the chartered accountant firms in Delhi page, or visit our office near the metro described on CA in Netaji Subhash Place.
Frequently asked questions
Is FC GPR filed by the company or the investor?
The Indian company that issues the equity instruments files FC GPR, through a business user on FIRMS. The authorised dealer bank verifies and forwards it. The foreign investor only supplies KYC details through the remitting bank.
Does the 30-day period run from receipt of money or allotment?
Regulation 4(1) says FC GPR must be filed not later than thirty days from the date of issue of equity instruments. Some guides mention other trigger dates; the regulation text uses the issue date, so treat the allotment date as the start of the clock.
What is the late fee for FC GPR?
RBI's late submission fee is ₹7,500 plus 0.025% of the amount involved multiplied by the years of delay, capped at the amount involved. It can be used for delays up to three years from the due date. Longer delays go through compounding.
Is a valuation certificate needed for every FC GPR?
A fair value certificate is the norm for issues by unlisted companies to non-residents. Some secondary sources say a rights issue at the price offered to residents may be treated differently. Ask your AD bank before filing if you think an exception applies.
What is FDI reporting in Form FLA?
FLA is the annual return on foreign liabilities and assets. Every Indian company or LLP that has received FDI or made overseas investment files it by 15 July each year, even if no new shares were issued during the year.
Can an NRI investment need FC GPR?
Yes, if an NRI subscribes to fresh shares on a repatriable basis and the issue counts as FDI. Investment on a non-repatriation basis is treated differently under the rules. Check the route with your AD bank before allotment.
What is the FC-TRS deadline?
FC-TRS must be filed within 60 days of the transfer of equity instruments or the receipt or remittance of funds, whichever is earlier. The resident party to the transfer files it on FIRMS through the AD bank.
Why do AD banks reject FC GPR forms?
Most rejections come from mismatches: investor name or amount different from the FIRC, missing KYC, wrong allotment date, an old valuation date, or the Entity Master not being updated. Check every figure against the source documents before submitting.
Do I need GST or income tax work after FDI?
Often yes. A company with foreign shareholders still files its normal returns, and payments to the foreign parent may need Form 15CA and 15CB. See our Form 15CA and 15CB page for remittances abroad.