Everything You Need to Know About FC-GPR

The Reserve Bank of India (RBI) has introduced an online application called FIRMS (Foreign Investment Reporting and Management System) to streamline the reporting of Form FC-GPR. FC-GPR stands for Foreign Currency – Gross Provisional Return, a form used to report Foreign Direct Investment (FDI) transactions.

This guide explains the FC-GPR filing procedure, legal provisions, checklist, and FAQs related to it.

What is FC-GPR?

When a business receives Foreign Direct Investment (FDI) through capital investment, it must issue shares to the foreign investor and report the transaction to the Reserve Bank of India (RBI) using Form FC-GPR.

As per RBI compliance for FDI, entities that issue shares against foreign investment must file Form FC-GPR within 30 days of allotment.

The term entity includes:
✔ Companies registered under Section 1(4) of the Companies Act, 2013.
✔ Limited Liability Partnerships (LLPs) under the Limited Liability Partnership Act, 2008.
✔ Startups that comply with Notification No. G.S.R 180(E) dated February 17, 2016 issued by the Department of Industrial Policy & Promotion (DIPP), Ministry of Commerce & Industry.

FDI Entry Routes

Foreign Direct Investment (FDI) is permitted under two routes:

1️⃣ Automatic Route: No prior government approval is needed. Non-residents and Indian companies can invest freely in permitted sectors.

2️⃣ Government Route: Requires approval from the respective Administrative Ministry/Department before investment.

When is Form FC-GPR Filing Required?

Entities must file Form FC-GPR in the following cases:

📌 At incorporation: If a shareholder is a non-resident, filing FC-GPR is mandatory as per RBI compliance.

📌 Upon receipt of share application money: Shares must be allotted within 60 days, and Form FC-GPR must be filed within 30 days of allotment.

Legal Provisions for FC-GPR Filing

✔ Compliance with RBI’s consolidated FDI policy – This includes sectoral caps, entry routes (automatic or approval), pricing guidelines, and more.
✔ Adherence to SEBI regulations, FEMA, and other applicable laws governing foreign investments.

Which Securities are Covered Under FC-GPR?

✔ Equity shares
✔ Convertible preference shares
✔ Convertible debentures

Steps for Filing Form FC-GPR

1️⃣ Register the business entity with RBI FIRMS Portal.
2️⃣ Login to FIRMS and then access the Single Master Form (SMF) section.
3️⃣ Select “Return Type” and fill in common investment details (date of share issue, shareholding pattern, etc.).
4️⃣ Provide foreign investment details.
5️⃣ Enter the total amount of inflow and the capital instruments issued.
6️⃣ Upload supporting documents (valuation report, declarations, approvals, etc.).
7️⃣ Verify the shareholding pattern (auto-populated).
8️⃣ Save and submit the form.

Required Attachments for Form FC-GPR

To successfully file Form FC-GPR, the following documents must be attached:

📌 KYC (Know Your Customer) documents.
📌 FIRC (Foreign Inward Remittance Certificate).
📌 Declaration by a verified representative of the Indian company.
📌 Company Secretary (CS) certificate in RBI-prescribed format.
📌 Pricing guidelines declaration.
📌 Declaration for conversion of CCPS (Compulsorily Convertible Preference Shares).
📌 Foreign Investment Promotion Board (FIPB) approval copy (if applicable).
📌 Valuation Report from a Chartered Accountant (CA) or Merchant Banker.
📌 Board Resolution for the allotment of securities with a list of allottees.

Foreign Liabilities and Assets (FLA) Reporting

✔ All Indian companies that receive FDI or make foreign investments abroad must file an annual return called Foreign Liabilities and Assets (FLA).
✔ The FLA return must be submitted by July 15th every year.

Introduction of the FLAIR System

To improve data security and accuracy, RBI is replacing the email-based FLA submission system with a web-based platform (FLAIR).

Key Features of FLAIR (Foreign Liabilities and Assets Information Reporting):

✅ Web portal interface (https://flair.rbi.org.in) for entity registration.
✅ Entity identification and user login credentials provided by RBI.
✅ Direct investment and financial details submission per fiscal year.
✅ System-driven validation checks to ensure data accuracy.
✅ Auto-generated acknowledgment receipt upon submission.
✅ Option to revise or view previous submissions.
✅ Submission of FLA for previous years requires RBI approval.

Why Compliance with RBI Regulations is Important?

Many businesses are unaware of RBI’s FDI compliance requirements. Failure to file Form FC-GPR within the deadline can result in heavy penalties.

Since reporting foreign investments is a complex process, RBI provides detailed user manuals to help businesses comply.

If you need assistance with FCRA Registration in Delhi or RBI reporting requirements, contact us at  [email protected]. Our team of experts ensures smooth and hassle-free compliance.