FC-GPR FDI Reporting

FC-GPR FDI Reporting

When a company in India issues shares or convertible securities to a foreign investor, RBI wants proof — and that proof is the FC-GPR. It confirms that the funds received have been converted into equity within the permitted timelines and pricing norms. Missing the filing is one of the most common FEMA violations.

What is FC-GPR?

A FEMA filing submitted through FIRMS-SMF when an Indian company allots shares or securities to a non-resident. It captures investor details, valuation, transaction date, sector, and shareholding after allotment.

When is it required?

  • Equity share allotment to foreign shareholders

  • CCPS, CCDs, share warrants, or similar convertible instruments issued to non-residents

  • Rights or bonus allotments involving foreign investors

  • ESOPs to overseas employees/directors

Timelines you must follow

  • Receive foreign funds

  • Allot shares within 60 days of receipt

  • File FC-GPR within 30 days of allotment

Why it matters

  • Mandatory under FEMA

  • Needed for future funding rounds and banking compliance

  • Avoids compounding, late fees, and regulatory queries

  • Clean paperwork helps during audits, due diligence, and mergers

What we assist with

  • FEMA eligibility and sectoral cap review

  • Valuation and pricing compliance

  • Preparing documents, certificates, and declarations

  • Filing FC-GPR on the FIRMS portal

  • Bank coordination and KYC follow-ups

  • Correcting earlier filings and delayed reporting regularisation

Documents typically required

  • COI, MoA, AoA

  • Board resolution and return of allotment

  • FIRC, KYC, and debit/credit advice from AD bank

  • Valuation certificate (CA/merchant banker)

  • Shareholding pattern and cap table

  • Declaration, CS certificate, and investor documents

Our filing process

  1. Understand the investment structure

  2. Review supporting documents and pricing rules

  3. Prepare and upload FC-GPR with attachments

  4. Coordinate with bank for verification

  5. Share acknowledgment and compliance record

Frequently Asked Questions

1. Is FC-GPR required even for small amounts?

Yes. Any foreign equity allotment — even minimal — must be reported.

 

2. Can FC-GPR be filed without completing EMF?

No. EMF approval is mandatory before SMF filings.

 

3. What if allotment wasn’t done within 60 days?

Refund the money or regularize under FEMA, depending on the case.

 

4. Do bonus or rights issues to foreign shareholders need FC-GPR?

Yes, if new shares are allotted to non-residents.

 

5. What happens if FC-GPR is filed late?

Possible FEMA violation, leading to compounding or penalties.