FC-GPR Filing in India 2026

If your Indian company has issued shares to a foreign investor, bought assets overseas, or received a remittance from a non-resident, the Reserve Bank of India expects a timely and accurate filing. Failure to report foreign exchange transactions under the Foreign Exchange Management Act 1999 attracts penalties that can run into lakhs of rupees, besides triggering a compliance red flag on your company's FEMA record. FC-GPR Filing is the statutory reporting mechanism that documents and regularises inbound foreign investment and certain outbound capital transactions. Under FEMA 20(R), the Master Direction on Foreign Investment in India, read with FEMA 30(R) on remittance of assets, every Indian entity that issues securities to a person resident outside India must file a report within 30 calendar days of the transaction. KAMRIT Financial Services LLP manages the complete FC-GPR filing lifecycle for you: from identifying the exact form and schedule applicable under current RBI Master Directions, to compiling the regulatory filing through the FIRMS portal, to tracking acknowledgment receipts and resolving post-filing queries from the Authorised Dealer bank. We handle the documentation, the portal submissions, and the follow-up so your compliance record stays clean.

What is FC-GPR Filing in India 2026?

FC-GPR stands for Foreign Currency, Gross Performance Report, though in practice RBI's reporting framework under FEMA treats it as the primary inbound investment reporting form for equity instruments. It is filed through the Foreign Investment Reporting and Management System (FIRMS), the digital portal maintained by the RBI under its FC-GPR and ARF (Annual Return on Foreign Assets and Liabilities) reporting framework. The legal basis sits in FEMA 20(R) (Master Direction No. 5 on Foreign Investment in India, updated July 2024) and FEMA 30(R) (Master Direction on Outward Remittance). Every Indian company that allots shares, partly paid shares, or convertible debentures to a non-resident investor, whether through the automatic route or the government approval route, must file an FC-GPR within 30 days of such allotment. The filing captures the nature of instrument, class of shares, face value, issue price, consideration received, country of investor, and percentage of equity held post-transaction. Separate reporting under Form FC-GPR is required for each distinct capital transaction. Annual reporting of the outstanding foreign liability position is done separately via the FLA return (due July 15 each year). FC-GPR is not a one-time compliance step, it is triggered every time fresh foreign capital enters the company.

Who needs this

FC-GPR filing is mandatory for Indian entities in any of the following scenarios. KAMRIT determines applicability based on the nature and route of the transaction, not merely the amount of investment.

• Indian company or body corporate that has issued equity shares or compulsorily convertible debentures to a non-resident under the automatic route under FEMA 20(R).
• Indian company that has received foreign investment under the government route (Sectors under government approval as per Press Note series of DPIIT).
• Start-up or MSME that has issued shares to a foreign venture capital investor, angel investor, or overseas family office.
• Indian entity that has issued partly paid-up shares to a non-resident where the balance call money is outstanding.
• Company that has made a rights issue or bonus issue where the allottee is a non-resident or foreign entity.
• Indian entity receiving foreign investment in the form of share warrants or optionally convertible debentures that have been exercised or allotted.
• Company undergoing change of shareholding pattern that results in a non-resident acquiring or increasing existing stake, even if no fresh capital is received.
• Indian subsidiary or joint venture company of a foreign parent that has received inter-company loans reclassified as equity instruments.

Documents required

RBI's FIRMS portal demands digitised originals or certified copies of every supporting document. KAMRIT's document checklist is built for the FIRMS upload format and the Authorised Dealer category bank's scrutiny requirements.

• RBI Acknowledgment of previous FC-GPR filings, if any (establishes continuity of reporting).
• PAS-3 filed with MCA for the relevant share allotment (MCA21 record of capital alteration).
• Share subscription agreement or share purchase agreement with the non-resident investor (shows consideration and terms).
• KYC of the foreign investor: passport copy, overseas address proof, PAN (if Indian origin), and latest audited balance sheet if a corporate entity.
• Board resolution authorizing the share issuance to a non-resident, with specific reference to FEMA provisions relied upon.
• Company's latest Audited Balance Sheet and Profit & Loss Account.
• Certificate from a Chartered Accountant confirming the fair value of shares issued, where the issue price exceeds face value (premium valuation).
• FIRMS FC-GPR form generated from the portal with completed fields in the prescribed template.
• Authorised Dealer category bank acknowledgment of the remittance (inward wire transfer confirmation with UTR number).
• Company's PAN card and registered office address proof (for cross-verification with MCA records).
• DPIIT approval letter or sectoral clearance, where the investment was under the government route.
• Share certificates or demat instruction memo confirming allotment.

How KAMRIT runs it, step by step

KAMRIT runs FC-GPR filings as a structured eight-step engagement from document collection to RBI acknowledgment.

1. Engagement kick-off and transaction review. KAMRIT's FEMA compliance team reviews the transaction, nature of investor, instrument type, investment route, and sector, to determine the exact FC-GPR form variant and applicable regulatory schedule. This review typically takes 1 working day. We identify any prior unreported transactions that need to be regularised alongside the current filing.
2. Document compilation and pre-filing audit. We collect all 12 document categories listed above and cross-check each against MCA21 records (SPICe+ Part B data, PAS-3 filings) and the Authorised Dealer bank's records. Any discrepancy in share price, allottee name, or amount triggers a correction cycle before portal upload. This stage takes 2 to 3 working days depending on document readiness.
3. FIRMS portal access and form preparation. KAMRIT logs into the RBI FIRMS portal using the company's designated FIRMS user ID. The FC-GPR form fields are populated with data from the board resolution, share subscription agreement, inward remittance UTR, and CA valuation certificate. CA digital signature is arranged for form authentication at this stage.
4. CA certification and digital signature. The FC-GPR form requires a Chartered Accountant to certify certain fields relating to the valuation of shares and compliance with FEMA pricing guidelines. KAMRIT coordinates with a empanelled CA for certification within 1 working day of form completion.
5. Portal submission and regulatory filing. The completed and certified FC-GPR is submitted on the FIRMS portal. KAMRIT retains the system-generated acknowledgment number and timestamp. The filing is confirmed within the 30-calendar-day statutory window from the date of allotment.
6. Authorised Dealer bank intimation. A copy of the FC-GPR acknowledgment and Form A2 (for capital account transactions) is submitted to the company's Authorised Dealer bank to update their records and release any held remittances.
7. RBI scrutiny and query management. RBI may raise queries on filings within 30 to 45 days of submission. KAMRIT manages all RBI correspondence, provides supplemental documentation, and resolves discrepancies on behalf of the client.
8. Filing closure and compliance certificate. Once RBI acknowledges the filing without further queries, KAMRIT issues a FEMA compliance certificate to the client confirming the transaction is reported, the 30-day window was met, and future reporting obligations (FLA return, subsequent FC-GPR triggers) are documented.

Timeline

From the date KAMRIT receives complete documentation, the FIRMS portal submission typically completes within 5 to 7 working days. The statutory 30-day window for filing is measured from the date of share allotment, not from KAMRIT's engagement date, so early engagement is critical. RBI's query resolution window, if triggered, adds 30 to 60 calendar days and is entirely regulator-controlled. If the filing involves a government-route investment or requires DPIIT intimation alongside FC-GPR, the DPIIT acknowledgment cycle adds another 15 to 20 working days. KAMRIT controls the pre-submission stages rigorously; the post-submission timeline is subject to RBI's internal processing queue. Realistically, an uncomplicated automatic-route FC-GPR filing takes 4 to 6 weeks from engagement kick-off to receipt of RBI acknowledgment. A filing involving prior-period irregularities or RBI queries can extend to 10 to 14 weeks. KAMRIT keeps clients updated at every RBI interaction point.

How our pricing compares

KAMRIT's FC-GPR Filing service starts at Rs 11,899 for a standard single-transaction filing under the automatic route with complete documentation provided upfront. This covers pre-filing review, FIRMS form preparation, CA coordination, portal submission, and one round of RBI query resolution. Government-route filings and filings requiring DPIIT intimation are quoted separately, typically ranging from Rs 18,000 to Rs 35,000 depending on complexity. IndiaFilings charges Rs 9,500 to Rs 14,900 for FC-GPR filing but quotes additional fees for MCA Form PAS-3 coordination and CA certification, pushing effective cost to Rs 16,000 to Rs 22,000. VakilSearch advertises Rs 8,500 as a base fee but excludes RBI query management and charges Rs 2,500 per query round. ClearTax focuses primarily on income tax and GST; its FEMA advisory fees for FC-GPR are Rs 15,000 to Rs 25,000, bundled into broader compliance retainers. LegalRaasta offers FC-GPR starting at Rs 7,500 but applies Rs 1,500 per document courier charge and charges separately for FIRMS portal access setup. KAMRIT's pricing bundles CA certification coordination, MCA cross-verification, and one full query-resolution cycle into the base fee, no hidden charges for portal upload or acknowledgment receipt. The difference reflects KAMRIT's end-to-end ownership model where one compliance officer manages the filing through completion rather than handing off to a CA and charging separately for coordination.

Common mistakes KAMRIT avoids

FC-GPR filings fail or attract RBI penalties most often because the transaction details on the form do not match what the Authorised Dealer bank has on record or what MCA shows in the share capital table. KAMRIT catches these before submission.

• Missing the 30-day filing deadline because the company assumes the statutory window starts from the date of receipt of the RBI acknowledgment of the remittance, not the date of allotment.
• Filing FC-GPR for a new issuance but forgetting to also file Form PAS-3 with MCA within the prescribed 30-day window under the Companies Act 2013.
• Incorrect instrument classification, reporting optionally convertible debentures as equity rather than as debt instruments, triggering a different FEMA schedule.
• Using the wrong FIRMS form: filing ARF (Annual Return) instead of FC-GPR for a primary share issuance, which does not satisfy the statutory reporting obligation.
• Not reporting subsequent changes to the non-resident shareholding, calls on partly paid shares, forfeiture, or buyback, which require fresh FC-GPR filings.
• Submitting without a CA-certified valuation when the issue price per share exceeds the face value, leading RBI to raise a pricing guideline query.
• Mismatched UTR number on FC-GPR: the Form A2 remittance UTR must match the FC-GPR form exactly, or the Authorised Dealer bank and RBI records will not reconcile.