FCGPR Filing in India — Complete Guide for Foreign Companies

What is FCGPR and why does it matter?

When a foreign company invests in an Indian subsidiary by subscribing to shares, that transaction must be reported to the Reserve Bank of India through Form FC-GPR. This is mandatory under FEMA 1999 and the Foreign Exchange Management (Non-Debt Instruments) Rules, 2019.

Failure to file FC-GPR within the prescribed timeline does not just attract a penalty — it can block future FDI tranches and create complications for remittance approvals.

When must FCGPR be filed?

FC-GPR must be filed within 30 days of the date of allotment of shares to the foreign investor. The date of allotment — not the date of receipt of funds — is the trigger.

For equity shares, compulsorily convertible preference shares (CCPS), compulsorily convertible debentures (CCD), and share warrants — all require FC-GPR filing.

Step-by-step FC-GPR filing process

Step 1: Receive FDI funds in the Indian company bank account through an Authorised Dealer bank. Step 2: Issue shares and pass a board resolution for allotment within 60 days of receipt of funds. Step 3: Obtain valuation certificate from a SEBI-registered Merchant Banker or Chartered Accountant. Step 4: File FC-GPR on the RBI FIRMS portal at firms.rbi.org.in. Step 5: Submit supporting documents including Board resolution, share certificate, MOA/AOA, FIRC, KYC of the foreign investor, and CA valuation certificate. Step 6: Obtain unique identification number from RBI upon successful submission.

Documents required for FC-GPR

The complete checklist includes: Form FC-GPR filled on FIRMS portal, Board resolution authorising share allotment, Share certificates issued to the foreign investor, FIRC from the AD bank confirming receipt of funds, KYC report of the foreign investor from the remitting bank, Valuation certificate from a Chartered Accountant or SEBI-registered Merchant Banker, Declaration by the authorised representative of the Indian company, and Copy of MOA showing objects clause covering the business activity.

What happens if you miss the 30-day deadline?

Late filing requires compounding with the RBI. The compounding amount is calculated as a percentage of the delayed FDI amount, with the rate depending on the nature and duration of the delay.

The compounding process itself takes 3-6 months and requires legal representation. During this period, the company may face difficulty in filing further compliances or making outward remittances.

FC-GPR vs FC-TRS — what is the difference?

FC-GPR is filed when a foreign investor subscribes to fresh shares from the Indian company (primary issue). FC-TRS is filed when existing shares in an Indian company are transferred between a resident and non-resident.

If your foreign parent is acquiring shares from an existing Indian shareholder rather than subscribing to new shares, you need FC-TRS, not FC-GPR.

Annual FLA return — the follow-on obligation

After FC-GPR is filed, the Indian company must file an Annual Return on Foreign Liabilities and Assets every year by July 15. The FLA return is filed directly on the RBI FLAIR portal. Missing the FLA return attracts a penalty of up to Rs. 1 lakh.

FCGPR filing has multiple moving parts — valuation, FIRMS portal registration, AD bank coordination, and tight deadlines. Our team handles the entire process end-to-end. Book a free consultation to discuss your FDI reporting requirements.