FC-GPR Filing Services – Reporting Foreign Direct Investment Received by Indian Companies Under FEMA

Q: What is Form FC-GPR under FEMA?

FEMA form filed on FIRMS within 30 days of allotting equity instruments to a foreign investor. Reports FDI amount, instrument type, issue price, allotment date, and investor details — primary transaction record of FDI.

Q: What is the 30-day deadline for FC-GPR filing?

30 days from the date of allotment of equity instruments — when the board resolves allotment and the allottee's name is entered in the register of members. Advance reporting to AD bank must precede allotment.

Q: What attachments are required with Form FC-GPR?

Valuation certificate (SEBI MB or CA), CS/CA allotment compliance certificate, board/shareholder resolution, KYC of foreign investor, and FIRC from AD bank confirming fund receipt.

Q: Does every FDI round require a separate FC-GPR?

Yes. Every allotment requires a separate FC-GPR within 30 days. Multiple investors on the same allotment date can be combined. Tranched allotments on different dates each need separate FC-GPR filings.

Q: Is FC-GPR required for allotment of shares under ESOP to non-residents?

ESOP allotments to non-resident employees require a specific ESOP reporting form on FIRMS — not strictly FC-GPR. Our team advises on the applicable reporting and manages the FIRMS portal filing.

FIRMS Portal FC-GPR Filing for FDI Received Through Share or Convertible Instrument Allotment Under FEMA 20(R)

Form FC-GPR (Foreign Currency – Gross Provisional Return) is the primary FEMA reporting form filed by Indian companies when they allot equity instruments — equity shares, fully and mandatorily convertible preference shares (CCPS), or fully and mandatorily convertible debentures (CCD) — to a person resident outside India as part of a Foreign Direct Investment transaction. Under Rule 5 of the Foreign Exchange Management (Non-Debt Instruments) Rules, 2019 (NDI Rules) and the corresponding Reporting Regulations, Form FC-GPR must be filed on the FIRMS portal through the company's AD Category-I bank within 30 days of the date of allotment of equity instruments to the foreign investor.

FC-GPR is one of the most compliance-sensitive FEMA filings — it is the first formal record of FDI received by an Indian company, and any error in the filing (incorrect pricing, wrong instrument classification, incorrect shareholder details) can trigger RBI enquiries and compounding. Our FC-GPR filing service covers the complete process from allotment documentation through valuation coordination, FIRMS portal submission, and AD bank liaison. This connects with our FC-TRS filing, FLA annual return, FDI overview, and FEMA consulting services.

Our FC-GPR Filing Services

FC-GPR Applicability and Instrument Assessment

Assessment of whether the FDI received requires FC-GPR filing — instrument eligibility (equity, CCPS, CCD), FDI classification, and sectoral cap compliance before allotment.

Advance Reporting to AD Bank

Preparation and filing of the advance reporting intimation with the company's AD Category-I bank within 30 days of receipt of the foreign inward remittance — the first step in the FC-GPR sequence.

Valuation Certificate Coordination

Coordination with a SEBI-registered Merchant Banker or Chartered Accountant for preparation of the FMV valuation report — required to certify that the issue price complies with FEMA pricing guidelines for foreign investors.

CS/CA Certificate for Allotment

Coordination with the Company Secretary or Chartered Accountant for the certificate confirming the allotment of equity instruments and compliance with the Companies Act — a mandatory FC-GPR attachment.

FIRMS Portal FC-GPR Submission

Preparation and submission of Form FC-GPR on the FIRMS portal within 30 days of the date of allotment — with all mandatory attachments including valuation certificate, allotment certificate, and board resolution.

Late FC-GPR Compounding

Advisory and compounding application for companies that have missed the 30-day FC-GPR filing deadline — including assessment of compounding fee liability and representation before the RBI Regional Office.

Why Accurate FC-GPR Filing Is the Foundation of FDI Compliance

FC-GPR is the primary record of FDI received — the FIRMS portal data from FC-GPR flows into the RBI's FDI database and is used in India's Balance of Payments statistics
Missed FC-GPR deadline (30 days from allotment) immediately creates compounding exposure — fees calculated at 0.025% to 0.05% per day on the FDI amount
Incorrect valuation in FC-GPR (below-FMV issue price) is a dual violation — both the pricing contravention and the reporting contravention attract separate compounding
FC-GPR data feeds directly into the FLA annual return — errors in FC-GPR create inconsistencies in the FLA that trigger RBI queries in subsequent years
In M&A and PE/VC fundraising, the FC-GPR filing history is verified in FEMA due diligence — missing FC-GPR filings are deal-blockers requiring compounding before transaction completion
Clean FC-GPR filing history across all funding rounds is a mark of professional FEMA compliance — valued by sophisticated foreign investors in subsequent fundraising rounds

Frequently Asked Questions

What is Form FC-GPR under FEMA?

Form FC-GPR (Foreign Currency – Gross Provisional Return) is the FEMA reporting form filed by Indian companies on the FIRMS portal within 30 days of allotting equity instruments (shares, CCPS, CCD) to a foreign investor as FDI. It reports the amount of FDI received, the instrument type and number, the issue price, the allotment date, and the foreign investor's details. It is the primary transaction-level record of FDI and serves as the basis for the RBI's recognition of the investment as compliant FDI.

What is the 30-day deadline for FC-GPR filing?

Form FC-GPR must be filed within 30 days of the date of allotment of equity instruments to the foreign investor. The allotment date is the date on which the company's board or allotment committee resolves to allot the shares and the allottee's name is entered in the register of members. The advance reporting to the AD bank (required within 30 days of receipt of foreign remittance) must have been completed before the allotment. The FIRMS portal submission must be completed by the end of the 30th day from the allotment date.

What attachments are required with Form FC-GPR?

FC-GPR mandatory attachments include: a valuation certificate from a SEBI-registered Merchant Banker (or CA for unlisted companies) confirming the FMV and that the issue price is not less than the FMV; a certificate from the Company Secretary or Chartered Accountant confirming that the allotment complies with the Companies Act and the company's articles; copy of the board resolution or shareholders' resolution authorising the allotment; KYC documents of the foreign investor; and the FIRC (Foreign Inward Remittance Certificate) issued by the AD bank confirming receipt of funds.

Does every FDI round require a separate FC-GPR?

Yes. Every individual allotment of equity instruments to a foreign investor — whether a new investor or an existing investor making a follow-on investment — requires a separate FC-GPR filing within 30 days of that specific allotment. If a company has a single funding round where shares are allotted to multiple foreign investors on the same date, one combined FC-GPR can be filed for that allotment. However, tranched allotments on different dates — even within the same funding round — each require separate FC-GPR filings.

Is FC-GPR required for allotment of shares under ESOP to non-residents?

ESOP-related allotments to non-resident employees of Indian companies have specific FEMA treatment. Where the ESOP is an employer-issued plan and shares are allotted directly by the Indian company to non-resident employees at an exercise price that complies with FEMA pricing norms, an ESOP filing on FIRMS is required (not strictly an FC-GPR but a separate ESOP reporting form). Our team advises on the specific reporting requirement applicable to the ESOP structure and manages the FIRMS portal filing.

File Your FC-GPR Accurately Within 30 Days of Allotment

Expert FC-GPR preparation, valuation coordination, FIRMS portal filing, and compounding advisory for FDI transactions.