FC-GPR filing 30-day clock: what triggers FEMA penalty interest in May 2026

The Foreign Currency Gross Provisional Return (FC-GPR) is the post-allotment FDI reporting form required under FEMA. Every Indian company that allots shares to a foreign investor must file FC-GPR on the RBI FIRMS portal within 30 days of the allotment.

The 30-day clock starts on the date of allotment, not the date of fund receipt. The May 2026 LSF schedule has steepened the cost of delay: up to 3 months delay is 7,500; 3-6 months is 22,500; 6-12 months is 37,500; 12-24 months is 52,500.

The substantive FEMA contraventions that LSF does not cure are: pricing below fair market value; breach of the sector cap; investment in a prohibited sector; and investment by an entity from a country sharing a land border with India without prior government approval under Press Note 3.

KAMRIT FEMA desk handles end-to-end FC-GPR filing including the valuation report coordination.