pvtltd.co

FEMA reporting

FC-GPR Filing for Startups After Foreign Investment

Just raised a funding round from a non-resident investor? You have 30 days from allotment of securities to file FC-GPR through RBI FIRMS.

Reviewed by CA Harun Raaj, ICAI Reg. No. 238303·Last reviewed:
Starting from INR 15,000 + GSTDeadlineFC-GPR foreign investment reporting

The funding round is not clean until the FEMA reporting is clean. We help startups reconcile the FIRC, board resolution, valuation certificate, investor KYC, allotment details, and FIRMS filing so the cap table is diligence-ready for the next round.

What is included
  • • FIRC and remittance trail review
  • • Allotment and board document check
  • • Valuation certificate compliance review
  • • Investor KYC checklist
  • • RBI FIRMS submission support
  • • Acknowledgement tracking
Documents required
  • • FIRC or bank advice for each remittance tranche
  • • Board resolution and allotment details
  • • Valuation certificate
  • • Investor KYC
  • • Company PAN, CIN, and authorised signatory details
Government fees

See the fee table below for the statutory filing charge and common delay logic.

Legal basis
  • • FEMA, 1999
  • • FEMA 20(R)/2017-RB foreign investment framework
  • • RBI FIRMS / Single Master Form reporting under A.P. (DIR Series) Circular No. 30 dated 7 June 2018
File FC-GPR - ₹15,000 + GSTExplore more services

Process

How the service works

The workflow is built to be predictable: document collection, legal review, filing, and post-filing follow-through.

Step 1Review

Map the round

We confirm investor residency, instrument type, allotment date, FDI route, and whether the sector has caps or approval conditions.

Step 2Evidence

Reconcile documents

The FIRC, valuation certificate, board papers, KYC, and cap table must match before FC-GPR is filed.

Step 3RBI

File on FIRMS

The FC-GPR is prepared in the Single Master Form workflow and routed through the AD bank.

Step 4Close

Track acknowledgement

We track queries, acknowledgement, and the UIN trail so the record is diligence-ready.

AEO summary

FC-GPR is the RBI reporting form filed after an Indian company issues equity instruments to a non-resident investor. The deadline is 30 days from allotment, not from signing the term sheet.

Why FC-GPR matters after funding

Foreign investment compliance is part of closing the round. A startup can have clean money, a signed SHA, and board approval, but still have a FEMA reporting issue if FC-GPR is missed.

The filing record becomes part of future diligence. The next investor will ask whether the earlier FDI was reported on time and whether the valuation and allotment trail match.

  • • 30-day FC-GPR clock starts from allotment.
  • • FIRC, valuation, KYC, and board records must align.
  • • Delayed reporting can trigger RBI LSF.

Government fees

Fee breakdown

ItemFeeNotes
FC-GPR filingINR 0RBI reporting itself usually has no statutory filing fee when filed on time.
Late Submission FeeVariableRBI LSF may apply for delayed reporting under A.P. (DIR Series) Circular No. 16 dated 30 September 2022.

Timeline

Typical turnaround

Deadline usually means a 30 days from allotment turnaround, assuming documents are complete and any board or shareholder approvals are already in place.

Pricing note

For a single investor round. Multi-investor or delayed filings may need a custom quote.

Related services

Keep the company moving

FDI compliance

Full post-investment reporting support across FC-GPR, FC-TRS, and FLA.

Increase authorised capital

Create share capital headroom before allotment.

Cap table management

Keep founder, investor, and ESOP holdings clean after the round.

FAQ

Frequently asked questions

When exactly is FC-GPR due after a funding round?
Under Rule 9 of the Foreign Exchange Management (Non-Debt Instruments) Rules, 2019, FC-GPR must be filed with RBI via the FIRMS portal within 30 days of the date of issue of equity instruments. The clock starts from the allotment date, not from the date the term sheet is signed or funds are received.
What documents are required to file FC-GPR?
The filing requires four core documents: (1) the Foreign Inward Remittance Certificate (FIRC) issued by the AD bank confirming the inward remittance, (2) KYC report on the foreign investor, (3) board resolution authorising the allotment, and (4) a valuation certificate confirming the issue price is not less than Fair Market Value computed under Rule 11UA of the Income-tax Rules, 1962. All four must reconcile before the Single Master Form is submitted on FIRMS.
Is RBI approval needed before issuing shares to a foreign investor?
For investments on the automatic FDI route, no prior RBI approval is required under the FEM (NDI) Rules, 2019. The investee company must confirm the sector is not on the prohibited list, sectoral caps are not breached, and any entry conditions under the applicable sectoral policy are met before allotment. Government-route sectors such as defence and print media still require prior government approval.
What is the penalty for filing FC-GPR late?
Late or non-filing is a contravention under FEMA, 1999 and attracts penalty under Section 13 of FEMA, which can be up to three times the amount involved. RBI also levies a Late Submission Fee (LSF) under A.P. (DIR Series) Circular No. 16 dated 30 September 2022, computed as a percentage of the outstanding reporting amount. Persistent non-compliance may lead to compounding proceedings or, for willful violations, criminal prosecution.
Who files FC-GPR, and through which portal?
The reporting obligation lies with the Indian company that receives the foreign investment, not the foreign investor. The company files FC-GPR through its Authorised Dealer (AD) Category-I bank on the RBI FIRMS portal using the Single Master Form workflow, as mandated by A.P. (DIR Series) Circular No. 30 dated 7 June 2018. The AD bank reviews and routes the submission to RBI, and the company receives a Unique Identification Number (UIN) on acknowledgement.

Canonical reference: https://www.pvtltd.co/services/fema-fc-gpr

Get started

Ready to move this filing forward?

We can help with the filing, the legal mapping, and the follow-up work that keeps the company compliant after submission.

File FC-GPR - ₹15,000 + GSTSee pricing