Who files FC-GPR, and when
The Indian company that issued the shares files FC-GPR. The investor does not file it.
Reporting is due within 30 days of the date of allotment. The route the investment came through does not change this: an automatic-route investment is reported in exactly the same form and window as a government-route one. The route decides whether approval was needed before the money came in, not whether reporting is needed after.
Report the issue in FC-GPR in each of these cases.
| What the company did | Reportable in FC-GPR | Notes |
|---|---|---|
| Allotted equity shares to a non-resident for cash | Yes | Pricing guidelines apply |
| Allotted fully and mandatorily convertible preference shares or debentures | Yes | Price or conversion formula fixed upfront, see issue of CCDs |
| Issued share warrants to a non-resident | Yes | Warrants are equity instruments under the NDI Rules |
| Issued bonus shares to an existing non-resident shareholder | Yes | Consideration type is reported as bonus |
| Allotted shares to the subscribers to the memorandum, one of whom is a non-resident | Yes | Report within 30 days of allotment |
| Allotted sweat equity to a non-resident | Yes | Value supported by the valuation |
| Transferred existing shares between a resident and a non-resident | No | That is Form FC-TRS, within 60 days, see FDI reporting |
| Issued convertible notes as a recognised startup | No | That is Form CN, within 30 days, see FDI reporting |
Optionally convertible and non-convertible debentures are not equity instruments. Money raised that way is borrowing and sits outside the FDI reporting framework, so do not file FC-GPR for it. See issue of debentures.
Fees
Professional fee: on quote. FC-GPR work is priced after we see the instrument, the number of investors and whether the reporting is already late.
Government fee: none. Filing FC-GPR on the FIRMS portal is free.
Late Submission Fee, shown separately because it is not a filing fee:
| Situation | Late Submission Fee |
|---|---|
| FC-GPR filed within 30 days of allotment | Nil |
| FC-GPR filed late | ₹7,500 plus 0.025% of the amount involved for each year of delay, capped at the amount involved in the delayed reporting |
| More than three years after the due date | The LSF route closes. The contravention is regularised through compounding with the Reserve Bank |
The LSF payment advice must be paid within 30 days of issue, or it lapses and the delay is recomputed.
Professional fees exclude GST at 18%. Government fees, where they apply, are paid at actuals to the department and are shown separately. Fees verified on 22 September 2026.
The filing, step by step
Most first filings are delayed by the portal registrations, not by the form.
| Step | What happens | Who does it | Timing |
|---|---|---|---|
| 1 | Entity user registration on FIRMS with the authority letter, so the company can maintain its entity master | Company, validated by the Reserve Bank | Before the first filing |
| 2 | Business user registration, submitted with the authority letter and PAN | Company, verified by your AD bank branch | Before the first filing |
| 3 | Board allots the shares and files PAS-3 with the ROC | Company | PAS-3 within 15 days of allotment |
| 4 | Valuation certificate obtained from a chartered accountant, a SEBI-registered merchant banker or a practising cost accountant | Certifier | Before allotment |
| 5 | FC-GPR prepared in the Single Master Form with the FIRC, investor KYC, board resolution and company secretary certificate | Regikart | Within 30 days of allotment |
| 6 | AD bank reviews the form and raises queries, then the Reserve Bank acknowledges it | AD bank and RBI | After submission |
| 7 | Acknowledgement filed in your records; FLA return diarised for 15 July | Regikart | Annual |
Documents we ask for: the FIRC or bank advice for the inward remittance, the investor's KYC from the remitting bank, the valuation certificate supporting the price, the board resolution and allotment details with PAS-3, a company secretary certificate in the prescribed format, and the shareholding pattern before and after the issue.
What holds up an FC-GPR
Four things account for most rejections and AD bank queries.
The FIRC or the bank advice names a remitter who is not the allottee. If the money came from a group entity or a nominee, the file needs an explanation the AD bank will accept before the form goes in.
The valuation does not support the price actually charged. The price to a non-resident cannot be below fair value, and for a convertible instrument the conversion price cannot be below the fair value worked out when the instrument was issued. See share valuation under Rule 11UA.
The entity master is out of date, so the shareholding pattern in the form does not tie to the last reported position.
The allotment itself is late. Under section 42 of the Companies Act, 2013 the company must allot within 60 days of receiving the application money, or refund it within the next 15 days with interest at 12% a year from the 60th day. A late allotment creates a Companies Act problem on top of the FEMA one.
FC-GPR and the filings around it
FC-GPR is one form in a set. Getting the others wrong is what turns a clean round into a compounding application.
| Event | Form | Due |
|---|---|---|
| Issue of equity instruments to a non-resident | FC-GPR | 30 days from allotment |
| Transfer of shares between a resident and a non-resident | FC-TRS | 60 days from the transfer or receipt of funds, whichever is earlier |
| Foreign investment in an LLP by capital contribution | LLP(I) | 30 days from receipt of the consideration |
| Investment by an Indian company owned or controlled by non-residents into another Indian company | DI | 30 days from allotment |
| Foreign liabilities and assets on the books at 31 March | FLA return | 15 July each year |
We cover the whole set on FDI reporting, and the annual return on FLA return.
Where the shares are allotted under an investment agreement, the reporting sits alongside the shareholders agreement. A cross-border transaction of ₹50 crore and above also needs an LEI: see LEI registration.