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FC-GPR and RBI Compliance

FC-GPR and RBI Compliance

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 – including sectoral caps, entry routes, and pricing guidelines.
  • ✔ 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

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

Required Attachments for Form FC-GPR

  • 📌 KYC documents.
  • 📌 FIRC (Foreign Inward Remittance Certificate).
  • 📌 Declaration by authorized company representative.
  • 📌 Company Secretary (CS) certificate (RBI prescribed format).
  • 📌 Pricing guidelines declaration.
  • 📌 Declaration for conversion of CCPS.
  • 📌 FIPB approval copy (if applicable).
  • 📌 Valuation Report from CA or Merchant Banker.
  • 📌 Board Resolution with list of allottees.

Foreign Liabilities and Assets (FLA) Reporting

  • ✔ Mandatory for Indian companies receiving FDI or making overseas investments.
  • ✔ Annual return to be filed by 15th July.

Introduction of the FLAIR System

RBI is replacing the email-based FLA submission system with a secure web-based platform called FLAIR.

Key Features of FLAIR

  • ✅ Web-based registration and login.
  • ✅ Entity identification through RBI credentials.
  • ✅ Financial year-wise submission.
  • ✅ System-driven validation checks.
  • ✅ Auto-generated acknowledgment receipt.
  • ✅ Option to revise or view previous filings.
  • ✅ RBI approval required for previous year submissions.

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 prescribed timeline can attract heavy penalties under FEMA.

Since reporting foreign investments is complex, RBI provides detailed manuals, and professional assistance is strongly recommended.

For expert assistance in FC-GPR filing, RBI compliance, and foreign investment reporting in Delhi, contact us at:
📧 admin@twindeskllp.com