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The Classic Partners LLP · FEMA & RBI

FDI Filing with RBI

Foreign money in the bank account is only half the transaction. The reporting that follows it has a 30-day clock and a valuation to support.

Quick answer

Foreign direct investment into an Indian company is reported to the RBI on the FIRMS portal — Form FC-GPR within 30 days of allotting capital instruments to a non-resident, and Form FC-TRS within 60 days where existing shares are transferred between a resident and a non-resident. The entity must first be registered on FIRMS as an Entity User and Business User, and delays are regularised through the Late Submission Fee mechanism rather than simply being left unreported.

What we cover

What our FDI reporting service covers

From sectoral eligibility to a filed, acknowledged return.

  • Sectoral eligibility, entry route and conditions under the NDI Rules
  • Entity User and Business User registration on the FIRMS portal
  • Form FC-GPR for issue of capital instruments to non-residents
  • Form FC-TRS for transfers between residents and non-residents
  • Valuation certificates and pricing guideline compliance
  • Late Submission Fee computation and payment for delayed filings
Key components

What an FDI filing actually needs

Four inputs, all of which take longer than the form itself.

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Route and sector check

Whether the sector is on the automatic or government route, the applicable cap, and any conditions attached to it.

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Inward remittance evidence

The FIRC and KYC report from the AD bank, tying the money received to the investor named in the filing.

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Valuation

A certificate supporting the issue or transfer price, prepared under an internationally accepted methodology by an eligible professional.

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FIRMS filing

The single master form filed within its window, with the company secretary's certificate and supporting declarations.

How we work

Our process

The sequence from remittance to acknowledgement.

1

Eligibility review

Confirming the sector, route, cap and conditions before any money is drawn down.

2

Documentation

Collecting the FIRC, KYC, valuation certificate, board and shareholder approvals.

3

FIRMS filing

Filing FC-GPR or FC-TRS within the prescribed window on the RBI's portal.

4

Closure

Tracking the filing to acknowledgement and building the record for the annual FLA return.

Why choose us

Where FDI reporting goes wrong

What sets our approach apart.

The allotment window is tight

Capital instruments must be issued within 60 days of receiving the funds, failing which the money is generally required to be refunded — and the reporting clock starts from allotment.

Pricing is not negotiable downward

A non-resident cannot be issued shares below the fair value determined under the pricing guidelines, whatever the parties have agreed commercially.

Delays are fixable, silence is not

The Late Submission Fee route allows most delayed filings to be regularised; ignoring the delay leaves an ongoing contravention that surfaces in diligence.

FAQs

FDI Filing with RBI questions answered

What people ask before engaging us.

FC-GPR is the return through which an Indian company reports the issue of capital instruments — equity shares, compulsorily convertible preference shares or compulsorily convertible debentures — to a person resident outside India. It is filed on the RBI's FIRMS portal by the Indian company, not by the investor.
FC-GPR is filed within 30 days of the date of allotment of the capital instruments. FC-TRS, which reports a transfer of existing instruments between a resident and a non-resident, is filed within 60 days of the transfer or of the receipt or remittance of funds, whichever is earlier.
Typically the foreign inward remittance certificate and KYC report from the AD bank, a valuation certificate supporting the price, the board resolution and list of allottees, a company secretary's certificate, and a declaration that the investment complies with the applicable sectoral conditions.
Delayed filings can generally be regularised by paying a Late Submission Fee, computed with reference to the amount involved and the length of the delay. Where a delay cannot be dealt with under that route, or where the underlying transaction itself contravenes the rules, the position is regularised through a compounding application to the RBI.

Received foreign investment recently?

We will confirm the route, the valuation position and the reporting deadline before the clock runs out.

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