By Manu Rao | Updated March 2026
What Is FC-GPR?
FC-GPR stands for Foreign Currency - Gross Provisional Return. It is a reporting form that every Indian company must file with the Reserve Bank of India (RBI) after issuing equity shares, compulsorily convertible debentures, or compulsorily convertible preference shares to a person resident outside India.
Think of it as the government's way of tracking every rupee of Foreign Direct Investment entering the country. Without FC-GPR, the RBI has no record that your company received foreign capital and issued shares against it.
Legal Basis
FC-GPR is prescribed under FEMA Notification No. 20(R)/2019-RB — the Foreign Exchange Management (Non-debt Instruments) Rules, 2019. The specific reporting requirement comes from Regulation 13 of these rules, read with the Master Direction on Reporting under FEMA (RBI/FED/2023-24/19, dated June 15, 2023).
The form is filed on the RBI's FIRMS (Foreign Investment Reporting and Management System) portal, which replaced the older eBiz and FC-GPR excel-based filing systems in 2018.
When Must You File FC-GPR?
File FC-GPR within 30 days of issuing shares to a foreign investor. The clock starts from the date of allotment recorded in the board resolution and Form PAS-3 filed with the Registrar of Companies.
FC-GPR applies when:
- An Indian company issues fresh equity shares to a foreign national, foreign company, or NRI/OCI investing on a repatriation basis
- Compulsorily convertible debentures (CCDs) are issued to a foreign investor
- Compulsorily convertible preference shares (CCPS) are allotted to a foreign holder
- Shares are issued under ESOP to employees who are persons resident outside India
- Bonus shares or rights shares are issued to existing foreign shareholders
FC-GPR is not required for transfer of existing shares between a resident and non-resident — that uses Form FC-TRS. And for downstream investments by Indian companies with foreign ownership, Form DI is used.
What Information Does FC-GPR Require?
The FIRMS portal asks for detailed data across multiple tabs:
Company Details
- CIN (Corporate Identity Number) of the Indian company
- Name, address, PAN, and sector of business
- Details of the Authorized Dealer (AD) bank
Investor Details
- Name and address of the foreign investor
- Country of incorporation/residence
- Unique identification number (passport, company registration)
- Whether the investor is from a country sharing a land border with India (Press Note 3 check)
Investment Details
- Amount of foreign inward remittance (in foreign currency and INR equivalent)
- FIRC (Foreign Inward Remittance Certificate) number and date
- Type of instrument issued (equity, CCD, CCPS)
- Number of shares/instruments, face value, and premium
- Pre-allotment and post-allotment shareholding pattern
- Fair Market Value as determined by the valuation report
Supporting Documents
- Board resolution for share allotment
- FIRC from the AD bank
- KYC documents of the foreign investor
- Valuation certificate from a SEBI-registered merchant banker or practicing CA (for unlisted companies)
- CS certificate or CA certificate confirming compliance
- Government approval letter (if government route applies)
Step-by-Step Filing Process
- Register on FIRMS portal — The Indian company (through its authorized signatory) registers at
firms.rbi.org.in. Registration requires the company's CIN, PAN, and AD bank details. - Create Entity Master — Enter company details, sector code (NIC code), and AD bank information. The AD bank must validate the entity on their end.
- Report the inward remittance — Before filing FC-GPR, the AD bank must first report the inward remittance on FIRMS. This generates a Unique Identification Number (UIN) for the transaction.
- Fill FC-GPR form — Enter investor details, instrument details, valuation, and shareholding pattern. Upload supporting documents as PDFs.
- AD bank verification — The AD bank reviews the filing and either approves or returns it for corrections.
- RBI acknowledgment — Once the AD bank approves, RBI generates an acknowledgment. The filing is complete.
Common Mistakes That Lead to Penalties
RBI compounding data shows FC-GPR violations are the single most common FEMA contravention. Avoid these errors:
- Filing after 30 days. Even a 1-day delay technically requires compounding. In practice, RBI compounding fees for late FC-GPR range from Rs 20,000 to several lakhs depending on the amount involved and length of delay.
- Incorrect valuation. For unlisted companies, shares must be valued using the Discounted Cash Flow (DCF) method by a SEBI-registered merchant banker, or using any internationally accepted pricing methodology by a practicing CA. The issue price cannot be below this valuation.
- Mismatched FIRC and allotment amounts. The remittance amount on the FIRC must match the consideration for shares. Exchange rate differences between remittance date and allotment date cause confusion — use the remittance date rate.
- Forgetting to update shareholding pattern. Post-allotment shareholding must be reported accurately. Errors here delay AD bank approval.
- Not filing at all. Some companies issue shares to foreign investors and simply forget to file. This surfaces during due diligence for subsequent funding rounds and causes serious problems.
Practical Example
A US-based SaaS company wants to set up an Indian subsidiary. The American parent incorporates an Indian Private Limited Company. It remits $200,000 to the Indian company's account with ICICI Bank (the AD bank).
ICICI Bank issues a FIRC and reports the inward remittance on FIRMS. The Indian company gets a valuation done — the CA values the company at par since it is newly incorporated. The board allots 2,00,000 equity shares of Rs 10 each at par on March 1.
The company's CS files FC-GPR on FIRMS by March 31 (within 30 days). ICICI Bank verifies and approves. RBI generates acknowledgment. Done.
If the company had missed the March 31 deadline, it would need to file a compounding application with RBI, admitting the delay and paying a compounding fee calculated under the RBI's compounding guidelines (Master Direction on Compounding of Contraventions under FEMA, 1999).
FC-GPR vs Other FEMA Forms
| Form | When to Use | Deadline |
|---|---|---|
| FC-GPR | Issuance of new shares/instruments to foreign investor | 30 days from allotment |
| FC-TRS | Transfer of existing shares between resident and non-resident | 60 days from transfer |
| LLP-I | Foreign investment in an LLP | 30 days from receipt of consideration |
| LLP-II | Disinvestment/transfer of LLP stake | 60 days from transfer |
| Form DI | Downstream investment by an Indian company with FDI | 30 days from allotment |
| Form ESOP | Issue of ESOP to non-residents | 30 days from issue |
Key Takeaways
- FC-GPR must be filed within 30 days of allotting shares to a foreign investor — no exceptions
- Filed on RBI's FIRMS portal, verified by your AD bank
- Valuation certificate is mandatory for unlisted companies
- Late filing is the most common FEMA violation — compounding fees apply
- Get your AD bank involved early; they must report inward remittance first
Need help filing FC-GPR for your company? Beacon Filing handles end-to-end FDI compliance.