Filings we handle
- FC-GPR — reporting the issue of shares or convertible instruments to foreign investors. Read the FC-GPR guide.
- FC-TRS — reporting transfers of shares between residents and non-residents. Read the FC-TRS guide.
- ODI filings — overseas direct investment into foreign subsidiaries or holding companies under the Overseas Investment Rules, 2022.
- Annual FLA return — the Foreign Liabilities and Assets return for companies with FDI or ODI.
- Valuation and pricing — fair-value certificates that satisfy FEMA pricing guidelines.
- RBI approvals and regularisation — approval-route cases, late-submission fees and compounding where something was missed.
- Companies Act, ROC and LLP compliance, and NBFC regulatory frameworks.
Key deadlines at a glance
| Event | Filing | Timeline |
|---|---|---|
| Shares / convertibles issued to a non-resident | FC-GPR (FIRMS portal) | Within 30 days of allotment |
| Transfer of shares between resident and non-resident | FC-TRS (FIRMS portal) | Within 60 days of transfer or receipt/remittance of funds, whichever is earlier |
| Company holds FDI and/or ODI | FLA return | Annually, by 15 July |
| Investment into a foreign entity | ODI forms via AD bank | As prescribed under the OI Rules/Regulations, 2022 |
Why it matters
FEMA reporting sits at the intersection of your AD bank, the RBI’s FIRMS portal, your company secretary and your valuer. Delays usually come from small mismatches — a FIRC that doesn’t match the allotment, a valuation dated after the issue, or a missing KYC. Late filings can be regularised by paying a late-submission fee, but repeated or long delays may need compounding and will be flagged in future due diligence.
Durgesh has handled FC-GPR reporting and ODI filings for venture-backed companies, including around a USD 3.75M Pre-Series A, and advises on cross-border structures through US Delaware, Singapore, DIFC and Mauritius holding companies.
Foreign company with an Indian subsidiary or Indian customers? See Indian subsidiary compliance and India tax for foreign companies.