FC-GPR and FC-TRS Filing on FIRMS

India, from Chennai+91 9176044244

An Indian company that issues shares to a non-resident reports it in Form FC-GPR within 30 days of allotment, and a transfer of shares between a resident and a non-resident is reported in Form FC-TRS within 60 days, both on RBI's FIRMS portal through the authorised dealer bank. We prepare the Rule 21 fair-value certificate, the filing and, where a deadline was missed, the late submission fee computation or compounding application.

What has to be reported, and by when?

Event	Filing	Time limit
Shares issued to a non-resident	Form FC-GPR on FIRMS	Within 30 days of issue
Transfer between a resident and a non-resident	Form FC-TRS on FIRMS, filed by the resident party	Within 60 days of the transfer or receipt or remittance of payment, whichever is earlier
Downstream investment by a foreign-owned Indian company	Form DI on FIRMS	Within 30 days of allotment
Company or LLP with foreign investment	Foreign Liabilities and Assets (FLA) return	By 15 July every year

Equity instruments must be issued within 60 days of receiving the money from the non-resident; if they are not, the money is refunded within 15 days after the 60 days end (Regulation 3.1 of the FEMA (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019). The investment must come through normal banking channels, and the bank's KYC of the remitter forms part of the FC-GPR filing.

How does filing on FIRMS work?

Steps on RBI's FIRMS portal

Entity master: the company registers on FIRMS and updates its entity master with the authorised dealer bank's confirmation
Business user: a business user is registered for the company to file the Single Master Form
Form: FC-GPR, FC-TRS, DI or the other forms are filed in the Single Master Form with the supporting documents
Bank review: the authorised dealer bank checks the filing, may raise queries, and approves it or forwards it to RBI
Acknowledgement: the approved form is the evidence that the investment was reported

What are the common reasons for rejection?

A valuation dated after the allotment or too far before it; a remitter name that does not match the investor; allotment beyond 60 days of receipt; shares issued below fair value; missing company secretary's certificate; and a sector or investor that needed government approval. We check each before filing.

What if a deadline was missed?

A reporting delay of up to three years is regularised by paying a late submission fee through the authorised dealer bank — ₹7,500 plus 0.025% of the amount involved for each year of delay, capped at the amount involved, or a flat ₹7,500 for the FLA return (A.P. (DIR Series) Circular No. 16 of 30 September 2022). Contraventions a late submission fee cannot cure — a share issue below fair value, allotment beyond 60 days without refund, or delays beyond three years — are compounded by RBI on an application to the Regional Office having jurisdiction over the registered office, filed physically or on RBI's PRAVAAH portal with a fee of ₹10,000 plus GST (Master Direction on Compounding of Contraventions, 22 April 2025). We prepare the computation or the compounding application.

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About V Viswanathan & Associates

Chartered Accountants, FRN 013713S— Practising since 2012 from G-131, Spencer Plaza, Anna Salai, Chennai.
IBBI Registered Valuer— Securities and financial assets, CA V. Viswanathan (IBBI/RV/03/2019/12333).
FCA, ACS, CFE— Company law, tax and forensic accounting under one roof.
Across India— Served from Chennai through video consultations and digitally signed reports and filings.

Frequently Asked Questions

What is the deadline for FC-GPR?

Within 30 days from the date of issue of the shares to the non-resident investor, filed on RBI's FIRMS portal and processed by the company's authorised dealer bank (Regulation 4(1) of the FEMA (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019). The shares themselves must be issued within 60 days of receiving the money, or the money refunded within 15 days after that.

Who files FC-TRS — the buyer or the seller?

The resident party to the transfer files Form FC-TRS, within 60 days of the transfer of the shares or the receipt or remittance of the payment, whichever is earlier.

What documents go with FC-GPR?

The foreign inward remittance certificate and the bank's KYC of the remitter, the fair-value certificate under Rule 21, a certificate from the company secretary on compliance with the Companies Act, and the board resolution and allotment details.

What if FC-GPR is late?

A delay of up to three years can usually be regularised by paying a late submission fee through the authorised dealer bank: ₹7,500 plus 0.025% of the amount involved for each year of delay (counted in months), capped at the amount involved, under RBI's A.P. (DIR Series) Circular No. 16 of 30 September 2022. A late FLA return attracts a flat ₹7,500. Longer delays and other contraventions are compounded by RBI on an application.

Do ESOPs to non-resident employees need reporting?

Yes. Shares or options issued to employees resident outside India are reported to RBI through the FIRMS portal within 30 days of issue.

Do you work with companies outside Chennai?

Yes. We work with companies across India from our office at Spencer Plaza, Anna Salai, Chennai, through video consultations, secure document sharing and digitally signed reports and filings. We do not have offices in other cities.

Law stated as at 27 Oct 2026. Official sources: FEMA and RBI directions (RBI), Companies Act, 2013 (MCA), Registered valuers (IBBI), Income-tax Act, 2025 and Rules, 2026 (CBDT). Reviewed by CA V. Viswanathan, FCA, ACS, CFE, IBBI Registered Valuer (IBBI/RV/03/2019/12333).