FC-GPR
RBI filing reporting share allotment to a foreign investor; due within 30 days of allotment.
What it stands for
- FForeign
- CCurrency
- GGross
- PProvisional
- RReturn
Regulator
Reserve Bank of India (RBI)
Deadline
Within 30 days of share allotment
Penalty
Compounding fee under FEMA Section 13: minimum INR 5000 plus...
Legal basis
Foreign Exchange Management Act, 1999
What is FC-GPR?
Form FC-GPR (Foreign Currency Gross Provisional Return) is the regulatory filing through which an Indian company reports the issue of capital instruments (equity shares, preference shares, convertible debentures or warrants) to a person resident outside India. The form is filed on the RBI's FIRMS portal (Foreign Investment Reporting and Management System) and is mandatory under the Foreign Exchange Management (Non-Debt Instruments) Rules, 2019.
FC-GPR is the first and most fundamental cross-border compliance for any GCC capitalised by a foreign parent. Without timely FC-GPR filing, the share allotment is technically defective, future capital infusions cannot be processed, and dividend repatriation is blocked. The filing requires supporting documents including the FIRC (Foreign Inward Remittance Certificate) from the receiving bank, KYC documentation, a CA certificate on pricing, and the board resolution authorising allotment.
- +Indian companies receiving FDI from foreign investors
- +Wholly-owned subsidiaries (WOS) of foreign parents
- +Joint ventures with foreign equity participation
- +Indian start-ups receiving foreign angel or VC capital
Statutory basis
Foreign Exchange Management Act, 1999
Section 6 read with FEMA (Non-Debt Instruments) Rules, 2019
Rule reference
Rule 4 of FEMA (NDI) Rules 2019; Master Direction on Reporting under FEMA
Notification
RBI Master Direction No. 18/2015-16 (as amended)
Enforced by
Reserve Bank of India (RBI), through FIRMS portal
Citations are editorially curated. Always verify current applicability with qualified Indian counsel before acting on a specific matter.
The stake
Filing window for FC-GPR. Skipping or mishandling this compliance carries direct financial and operational consequences.
Why FC-GPR matters for your GCC
FC-GPR is the single most important compliance for any newly capitalised GCC. A delayed or missed FC-GPR creates a FEMA contravention that compounds monthly and blocks all future RBI dealings including subsequent capital raises, ESOP grants to foreign-residents, ECB borrowings, and dividend repatriation. Most foreign parents discover the issue only when attempting their first dividend distribution, at which point the contravention period and penalty have grown materially.
The 4 ways FC-GPR goes wrong
Real scenarios from real GCC compliance audits. Each one preventable.
Trap 01
Filing after the 30-day window without seeking compounding, then attempting another transaction that surfaces the prior contravention
Trap 02
Filing FC-GPR without obtaining and attaching the FIRC from the AD bank within the same timeframe
Trap 03
Pricing the share issue below the floor under the FEMA pricing guidelines, requiring re-pricing and re-filing
Trap 04
Using incorrect Activity Code or NIC code on the FIRMS portal, leading to filing rejection and missed deadline
Done for you
FEMA and RBI Compliance Service
IRPR Network handles FC-GPR preparation, FIRMS portal filing, CA pricing certification, and bank coordination for every capital event in your GCC lifecycle.
Our workflow
- 01Identify the trigger event in your GCC operations
- 02Prepare and validate the FC-GPR filing or compliance step
- 03Submit to the regulator and obtain acknowledgement
- 04Track in your compliance calendar for ongoing or recurring obligations
Concepts connected to FC-GPR
These terms are filed together, depend on each other, or share regulatory authority.
FEMA and RBI
FEMA
The Indian law governing all cross-border foreign exchange transactions, replacing FERA in 1999.
FEMA and RBI
FDI Automatic Route
FDI route allowing 100 percent foreign investment without prior government or RBI approval, subject to sectoral caps.
FEMA and RBI
FLA Return
Annual RBI filing reporting foreign liabilities and assets of Indian companies; due 15 July each year.
MCA and ROC
SPICe+
Single integrated MCA21 form for company incorporation, replacing multiple separate registrations.
Asked about FC-GPR
4 specific questions that GCC operators ask most often, answered with citations to the relevant regulations.
Need help with FC-GPR?
IRPR Network manages FC-GPR as part of FEMA and RBI Compliance Service, with a zero-penalty guarantee.
Explore the serviceQ01What happens if FC-GPR is not filed within 30 days of share allotment?
+
Late filing is a FEMA contravention under Section 13. The company must apply to RBI for compounding, paying a fee that includes a base amount plus 0.075 percent per month of the FDI value. Until the contravention is compounded, the company cannot complete subsequent RBI transactions including FLA return, ECB filings, or dividend repatriation.
Q02Is FC-GPR required for every capital infusion, or only the first one?
+
FC-GPR is required for every issue of capital instruments to a person resident outside India. Each fresh allotment of equity, preference shares, convertible debentures or warrants triggers a separate FC-GPR within 30 days. Conversion of debentures to equity also requires a fresh FC-GPR filing.
Q03Who can file FC-GPR - the company, the bank, or the CA?
+
The Indian company is the responsible filer through the FIRMS portal. The Authorised Dealer (AD) bank that received the inward remittance provides the FIRC. A Chartered Accountant certifies the share pricing under FEMA pricing guidelines. Most GCCs delegate the end-to-end process to a compliance partner; IRPR Network handles all three coordination points.
Q04What documents must accompany an FC-GPR filing?
+
FIRC from the AD bank, KYC of the foreign investor, board resolution authorising allotment, CA certificate on pricing, copy of the share allotment letter, and the e-Form FC-GPR generated from FIRMS. For convertible instruments, additional pricing valuation reports are required.
Handle FC-GPR the right way, the first time.
Book a 30-minute consultation. We will map your FC-GPR obligations alongside every other India compliance for your GCC, on one calendar, one retainer.
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