FEMA Compliance · FC-GPR & FDI Reporting

FC-GPR FDI Reporting report every foreign direct investment to the RBI within 30 days and stay on the right side of FEMA.

Form FC-GPR (Foreign Currency — Gross Provisional Return) must be filed with the RBI through the FLAIRS portal within 30 days of allotting shares to a foreign investor — making it one of the most time-critical compliance obligations for any Indian company receiving foreign direct investment.

When an Indian company allots shares — equity, CCPS, or other FEMA-compliant instruments — to a person resident outside India, it must report this transaction to the Reserve Bank of India by filing Form FC-GPR on the FLAIRS portal within 30 days of the date of allotment. This applies whether the investment is made under the automatic route or the government approval route, and regardless of the amount involved.

The FC-GPR filing requires the company's Authorised Dealer bank to verify and certify the inward remittance before the form can be submitted. The filing must include the valuation report, share allotment details, KYC of the foreign investor, FIRC or debit certificate, and the updated Stake Master Form (SMF) on the FLAIRS portal. Missing the 30-day deadline is a FEMA contravention that must be compounded with the RBI before the next regulated transaction can proceed.

At Beyonte Compliances, we manage the complete FC-GPR filing process — from post-allotment documentation through to AD bank coordination and portal submission — ensuring every foreign investment event is reported to the RBI correctly and within the statutory deadline.

What Our FC-GPR Filing Service Covers

Post-Allotment Document Collection

Gathering all documents required for the FC-GPR filing — allotment resolution, share certificates, FIRC/debit advice, valuation report, and investor KYC.

FLAIRS Portal SMF Update

Updating the Stake Master Form on the FLAIRS portal to reflect the new investor and shareholding position before initiating the FC-GPR filing.

FC-GPR Form Preparation

Completing the FC-GPR form on the FLAIRS portal with accurate investment details, instrument classification, consideration, and share allotment data.

AD Bank Coordination & Certification

Coordinating with the company's Authorised Dealer bank to obtain FIRC/debit confirmation and the AD bank's certification required for submission.

FEMA Pricing Compliance Review

Verifying that the share issue price complies with FEMA pricing guidelines — specifically that it is not less than the fair market value determined by a registered valuer or merchant banker.

Filing & Acknowledgement

Submitting the FC-GPR on the FLAIRS portal within the 30-day deadline and obtaining the unique identification number (UIN) as the filing acknowledgement.

Compounding for Delayed FC-GPR

Preparing and filing RBI compounding applications for FC-GPR filings that have been missed or delayed beyond the 30-day deadline.

Multi-Tranche Investment Management

Managing FC-GPR compliance for phased or multi-tranche investment rounds where separate filings are required for each allotment tranche.

Our Process

Allotment Confirmation & Timeline Check

Confirming the date of allotment and calculating the 30-day FC-GPR deadline to establish the filing timeline for the engagement.

Document Collection & Verification

Gathering and reviewing all required documents — FIRC, valuation report, board resolution, share certificates, and investor KYC — for completeness.

SMF Update on FLAIRS

Updating the Stake Master Form on the FLAIRS portal to reflect the new shareholder and shareholding percentage post-allotment.

AD Bank Certification & Portal Filing

Coordinating with the AD bank for certification of the inward remittance and filing the FC-GPR on the FLAIRS portal before the deadline.

UIN Receipt & Record Update

Obtaining the FLAIRS UIN as filing confirmation and updating the company's FEMA compliance register with all filing details and acknowledgements.

Why It Matters

✓Timely FC-GPR filing avoids compounding liability that can be substantial for high-value investments

✓Correct pricing compliance protects the company from characterisation of the shortfall as a FEMA violation

✓Complete FC-GPR record is the primary evidence of FEMA-compliant FDI during investor due diligence

✓SMF updated simultaneously with FC-GPR maintains a consistent and accurate FLAIRS portal record

✓AD bank coordination ensures the remittance certification is obtained without delays in the filing timeline

✓Compounding of delayed filings regularises the record before the next fundraising round

✓Multi-tranche management ensures each allotment in a phased round is separately and correctly filed

✓FLAIRS UIN provides the company with a permanently accessible record of each investment event

Frequently Asked Questions

Form FC-GPR (Foreign Currency — Gross Provisional Return) is the RBI reporting form filed by an Indian company when it allots shares or other FEMA-compliant instruments to a foreign investor. It must be filed on the FLAIRS portal within 30 days of the date of allotment of shares, and is required for every FDI transaction regardless of the investment amount.

Required documents include the Foreign Inward Remittance Certificate (FIRC) or bank debit advice confirming receipt of funds, the share allotment resolution and share certificates, a valuation report from a SEBI-registered Merchant Banker or Registered CA confirming the issue price, the investor's KYC documents, and the updated SMF on the FLAIRS portal reflecting the new shareholding.

The RBI compounding amount for delayed FC-GPR filings is calculated based on the amount involved and the period of delay. The RBI's compounding matrix considers the transaction value, delay in months, and the applicable percentage — which can be significant for high-value investments delayed by multiple years. Compounding fees are charged separately for each delayed filing.

Convertible notes issued by DPIIT-recognised startups to foreign investors have a separate reporting requirement under the FEMA (Non-Debt Instruments) Rules — the entity must file the reporting form for the convertible note issuance through the AD bank within the prescribed timelines. FC-GPR is filed separately when the note is converted into equity shares at the next priced round.

File your FC-GPR within 30 days of every share allotment — without exception.

Talk to our team about managing FC-GPR compliance for your current or upcoming foreign investment round.