FC-GPR and FC-TRS Filing in India

What is FC-GPR?

FC-GPR is the RBI form for reporting the issue of equity instruments by an Indian company to a person resident outside India, where the issue counts as foreign direct investment. It covers the first subscription when a foreign parent capitalises a new wholly owned subsidiary, later rights issues, conversions of convertible instruments and shares issued to NRIs on a repatriation basis.

The investment itself is governed by the Foreign Exchange Management (Non-Debt Instruments) Rules, 2019, which set the entry routes, sectoral caps and pricing guidelines. The mode of payment and the reporting are governed by the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019, as amended, including the January 2025 amendment.

What are the FC-GPR and FC-TRS time limits?

How do you file FC-GPR on the FIRMS portal?

1. 1

   Check the FDI route and sector cap

   Confirm the activity is under the automatic route and within the sectoral cap, or obtain government approval first.

2. 2

   Receive funds through banking channels

   Receive the investment from abroad into the company's bank account and obtain the FIRC and investor KYC from the authorised dealer bank.

3. 3

   Value and allot within 60 days

   Obtain a valuation under the pricing guidelines and allot the shares within 60 days of receiving the funds; refund within 15 days after that if not allotted.

4. 4

   Register on FIRMS

   Create the business user and complete the Entity Master on the RBI's FIRMS portal if not already done.

5. 5

   File FC-GPR within 30 days

   File FC-GPR in the Single Master Form within 30 days of allotment, with the supporting documents, for the bank and RBI to process.

Which documents are needed for FC-GPR?

• Foreign Inward Remittance Certificate (FIRC) and KYC of the non-resident investor from the authorised dealer bank
• Board resolution approving the allotment, and the allotment details
• Valuation certificate showing the issue price complies with the pricing guidelines under the Non-Debt Instruments Rules
• Declaration by the company secretary or authorised signatory on compliance with the FDI conditions
• Memorandum and articles, and government approval where the activity is under the approval route

The authorised dealer bank reviews the filing first and may raise queries before it reaches the RBI. Most delays come from mismatches between the FIRC, the bank statement, the valuation and the allotment details, so reconcile them before filing.

What is FC-TRS and when is it triggered?

FC-TRS reports a transfer of equity instruments between a person resident in India and a person resident outside India, in either direction. Typical triggers are a founder selling shares to a foreign investor, a foreign parent buying out an Indian joint venture partner, or a non-resident exiting to a resident buyer. Transfers between two non-residents generally do not need FC-TRS, and transfers on a non-repatriation basis follow separate rules.

The price must comply with the pricing guidelines, and the funds must move through banking channels. The onus of filing is generally on the resident party, which is why Indian promoters selling to a foreign buyer need to plan the filing as part of the deal timetable. For the full deal process, see acquiring an Indian company.

What happens if FC-GPR or FC-TRS is filed late?

Regulation 5 of the reporting regulations makes the person responsible for the filing liable to pay a late submission fee decided by the RBI. More serious or longer delays, or other contraventions such as issuing shares after the 60-day window, may need compounding with the RBI. Missing filings usually come to light in a fund-raise, a transfer, an FLA return mismatch or an acquirer's due diligence.

We review the company's foreign investment history, file pending forms with the late submission fee where available, and prepare compounding applications where needed. See also FDI entry routes, NRI investment and FEMA compliance and post-incorporation compliance.

Sources: Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019 (Notification FEMA 395/2019-RB), regulations 3, 4 and 5, as amended by Notification FEMA 395(3)/2025-RB of 14 January 2025; Foreign Exchange Management (Non-Debt Instruments) Rules, 2019; RBI FIRMS portal. Last reviewed: November 2026 · Reviewed by CA Regi Tom Antony, Regi Tom Antony & Associates. General guidance, not advice on a specific transaction.