Which form reports what
Start from the event, not from the form. Each row is a separate reporting obligation with its own clock.
| Event | Form | Who files | Due |
|---|---|---|---|
| Indian company issues equity instruments to a person resident outside India | FC-GPR | The Indian company | 30 days from allotment |
| Shares transferred between a resident and a non-resident, either way | FC-TRS | The resident party to the transfer | 60 days from the transfer or from receipt of funds, whichever is earlier |
| Foreign investment into an LLP by capital contribution or profit share | LLP(I) | The LLP | 30 days from receipt of the consideration |
| Disinvestment or transfer of an LLP interest involving a non-resident | LLP(II) | The LLP | 60 days from receipt of funds |
| Convertible notes issued or transferred by a recognised startup | Form CN | The issuing or transferring party | 30 days |
| Employee stock options granted to an employee resident outside India | Form ESOP | The Indian company | 30 days from the grant |
| Downstream investment by an Indian company owned or controlled by non-residents into another Indian company | Form DI | The investing Indian company | 30 days from allotment |
| Depository receipts issued or transferred | Form DRR | The issuing or transferring party | 30 days from the close of the issue |
| Foreign liabilities and assets on the balance sheet at 31 March | FLA return | Every company, LLP, AIF or firm holding them | 15 July every year |
Equity instruments, for FC-GPR, means equity shares, fully and mandatorily convertible debentures, fully and mandatorily convertible preference shares and share warrants. Optionally convertible or non-convertible instruments are borrowing, not FDI, and are not reported in these forms.
The detail for the two commonest filings is on our FC-GPR filing and FLA return pages.
Fees
Professional fee: on quote. Reporting work is priced by the number of events, the number of investors and whether any filing is already late.
Government fee: none. There is no filing fee for FC-GPR, FC-TRS, LLP(I), LLP(II), CN, ESOP, DI or the FLA return on the RBI portals.
Late Submission Fee, kept separate because it is not a filing fee:
| Type of reporting | Late Submission Fee |
|---|---|
| Transaction forms: FC-GPR, FC-TRS, LLP(I), LLP(II), CN, ESOP, DI | ₹7,500 plus 0.025% of the amount involved for each year of delay, capped at the amount involved |
| Recurring returns: FLA return, FC-GPR Part B, annual performance report | ₹7,500 flat |
| Due date more than three years old | LSF is no longer available. The default is regularised by compounding with the Reserve Bank |
The years of delay are computed to two decimal places, and the LSF payment advice lapses if it is not paid within 30 days.
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.
Before the reporting: the entry conditions
Reporting is the last step, not the first. Two checks come before the money arrives.
Is the sector open, and on which route? The FEMA (Non-debt Instruments) Rules, 2019 set out the sectors where foreign investment is prohibited, the sectors with a cap, and the sectors that need government approval before the investment. Where approval is needed, it is obtained first; reporting still happens afterwards in the same form and the same window.
Is the price right? The price to a non-resident must not be less than the fair value worked out by any internationally accepted pricing methodology on an arm's length basis. For an unlisted company the certificate may be issued by a chartered accountant, a SEBI-registered merchant banker or a practising cost accountant. For convertible instruments, the price or conversion formula is fixed upfront and the conversion price cannot be below the fair value at the time of issue.
On the way out, the same test runs in reverse: a transfer from a resident to a non-resident cannot be below fair value, and a transfer from a non-resident to a resident cannot be above it. See share valuation under Rule 11UA.
How the portal is set up
| Step | What happens | Who does it |
|---|---|---|
| 1 | Entity user registration on FIRMS with an authority letter, which lets the entity maintain its entity master | Company or LLP, validated by the Reserve Bank |
| 2 | Business user registration with the authority letter and PAN | Company or LLP, verified by your AD bank branch |
| 3 | Entity master brought up to date with every past foreign investment | Regikart |
| 4 | Event-wise filings prepared in the Single Master Form with supporting certificates | Regikart |
| 5 | AD bank review, queries, then Reserve Bank acknowledgement | AD bank and RBI |
| 6 | Reporting calendar set up: event forms as they arise, FLA return by 15 July | Regikart |
A new company that has just received its first inward remittance usually loses a week on steps 1 and 2 alone, so start them the day the investment is agreed, not the day the money lands.
Where FDI reporting goes wrong
Late allotment. Under section 42 of the Companies Act, 2013, application money must be allotted against within 60 days, or refunded within the next 15 days with interest at 12% a year from the 60th day. A company that sits on foreign money for a quarter has a Companies Act default before it has a FEMA one.
Remitter and allottee do not match. If funds came from a parent or a nominee, the file needs an explanation your AD bank will accept. Where the AD bank asks for a Legal Entity Identifier on a cross-border transaction, see LEI registration for the RBI thresholds.
Downstream investment ignored. An Indian company that is owned or controlled by non-residents and then invests in another Indian company has its own Form DI to file, within 30 days. This is the most commonly missed form in group structures.
The FLA return forgotten in a quiet year. The obligation runs on the balance sheet, not on transactions: if foreign investment or overseas investment is still on the books at 31 March, the return is due by 15 July even if nothing happened all year.
Share transfers treated as an internal matter. A transfer of shares between a founder and a foreign investor is reportable in FC-TRS by the resident party, on top of the SH-4, stamp duty and board approval. See share transfer.