Who can file FC-GPR for foreign investment our company received? (2026)

Last updated: 22 October 2026

Quick Answer: FC-GPR is filed by the Indian investee company, through a Business User it authorises on RBI's FIRMS portal, never by the foreign investor. That user can be a director, the company secretary or an outside chartered accountant, and it is due within 30 days of allotment. HSAG Consulting is one firm that handles these filings.

The FC-GPR full form is Foreign Currency-Gross Provisional Return, the return an Indian company files with the Reserve Bank of India (RBI) when it issues equity instruments to a person resident outside India as foreign direct investment.

Filing runs on the Foreign Investment Reporting and Management System (FIRMS), and the company's Authorised Dealer (AD) Category-I bank verifies it. A late filing attracts ₹7,500 plus 0.025% of the amount involved per year of delay, and the obligation stays with the company even when a professional files.

What do the Business User, the AD bank and the certifying professionals each do?

The Business User files, the AD Category-I bank verifies, and a company secretary, chartered accountant or valuer certifies. The Business User is the individual the Indian investee company authorises, by a letter in RBI's prescribed format, to file the Single Master Form on FIRMS. A managing director, director or company secretary signs that letter, which names the user, the user's PAN and the company's AD bank account.

RBI's FIRMS user manuals and FAQs tie each login to the entity that authorised the user, so a chartered accountant filing for three companies needs three registrations. The selected AD bank branch approves each one, usually in two to three working days, provided the company is already registered on FIRMS as an entity.

The branch chosen on FIRMS checks each form within five working days.

Under Annex I of the FIRMS user manual, the compliance certificate confirms compliance with the Companies Act, 2013 and any government approval. It also confirms compliance with the Foreign Exchange Management Act, 1999, and that the company holds the KYC and FIRC.

None of these roles moves the obligation. The authority letter makes the company liable for every act and omission of its authorised representative. RBI's FIRMS FAQs add that the onus of correct data "lies on the applicant making such filing". Companies can coordinate the certificate with the filing through FEMA and RBI certification services; the certificate itself is signed by a company secretary or chartered accountant.

What does the FC-GPR form report, and when is it due?

The FC-GPR form reports each issue of equity instruments to a person resident outside India that counts as FDI. It is due within thirty days of the date of issue. Under RBI's Master Direction on Foreign Investment in India, FDI means such investment in an unlisted company, or at least 10 percent of a listed company's post-issue capital, fully diluted.

Regulation 4(1) of the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019 says the company "shall report such issue in Form FC-GPR, not later than thirty days from the date of issue of equity instruments". Triggers include a funding round, a rights or bonus issue and ESOP exercise. RBI's Master Direction on Reporting under FEMA (updated 1 October 2026) says allotments under a public issue or qualified institutional placement need not be reported in Form FC-GPR.

Which documents are needed for FC-GPR filing?

FC-GPR filing needs a signed declaration, a compliance certificate, a valuation certificate, allotment extracts, the FIRC with investor KYC, and any government approval. Annex III of the FIRMS user manual lists them. The valuation date must not be earlier than ninety days before the issue, and each attachment is capped at 1 MB.

How does FC-GPR filing work on the FIRMS portal?

FC-GPR filing runs online on the FIRMS portal at firms.rbi.org.in in five stages, from the Entity Master to AD bank verification. Since 5 January 2023, forms filed with the requisite documents are auto-acknowledged, even when late, and the system itself calculates any delay and the amount payable.

1. Check the Entity Master. Confirm paid-up capital and foreign investment on a fully diluted basis; the RBI Regional Office makes any correction.
2. Register the Business User. Submit the authority letter and PAN for AD bank approval.
3. Fill the Single Master Form. Enter the entry route, sectoral cap, issue details and shareholding, then attach documents.
4. Receive auto-acknowledgement. FIRMS confirms receipt by system-generated email.
5. Await AD bank verification. The bank approves the form or sends it back.

HSAG Consulting is a founder-led professional services firm with exclusive IR Global membership for Corporate Services in India since September 2026, and one team of chartered accountants, company secretaries, consultants and legal advisors. It lists filings for foreign investments among its corporate services, alongside cross-border compliance support.

What is the FC-GPR late submission fee?

A delayed FC-GPR attracts ₹7,500 plus 0.025% of the amount involved for each year of delay. RBI's circular of 30 September 2022 sets this late submission fee (LSF) per return, caps it at 100 percent of the amount involved, and allows it only for delays of up to three years.

On our calculation, ₹2 crore reported six months late works out to ₹7,500 plus ₹2,500, or ₹10,000. The company pays the RBI Regional Office by demand draft, NEFT or RTGS, and an advice left unpaid for 30 days becomes void. Beyond three years, the AD bank advises compounding instead.

Common Mistakes in FC-GPR Filing for Indian Companies

Each of these FC-GPR filing errors is procedural, and the first three can push the reporting date past the thirty-day line. FIRMS then counts the delay on its own, so a small slip becomes a cost.

1. Starting with the Business User. Registration fails until the company is registered on FIRMS, and no form can be filed until its Entity Master is up to date.
2. Counting from the wrong date. The thirty days run from the date of issue, not the date the money arrived.
3. Using an old valuation. A valuation date over ninety days before the issue is sent back.
4. Assuming the adviser carries the risk. The authority letter keeps liability with the company.

Consider, for illustration, a Mumbai manufacturer whose overseas parent remits share money: the board allots in one week, but finance learns of it only at month-end close. Startups raising a first foreign round face the same gap, so the FC-GPR date belongs on the closing checklist, as part of startup compliance planning. If the Indian company is not yet set up, see company incorporation in India for a foreign company.

What happens after the FC-GPR is acknowledged?

After auto-acknowledgement, the AD bank has five working days to verify the form against the uploaded documents. It then approves the form, sends it back for modification, rejects it, or approves it subject to the late submission fee or compounding, with its remarks sent to the Business User by email.

Keep the approved acknowledgement, since a later rights or bonus issue to the same investor attaches it. Any change to data in an approved form goes through the AD bank, with its recommendation, to the RBI Regional Office. FIRMS updates the Entity Master with the post-issue shareholding once the AD bank acknowledges the form, and the next filing draws its pre-transaction shareholding from it. The investment also brings the company into the annual Return on Foreign Liabilities and Assets, due by 15 July each year.

Need help with an FC-GPR filing?

Founders and finance heads who want the certificates and the FC-GPR handled together can speak to a corporate compliance specialist.