- FC-GPR due date: within 30 days of allotting shares to a foreign investor, on RBI’s FIRMS portal.
- Before allotment: the money must come in through banking channels and shares should be allotted within 60 days of receipt.
- Missed it? File late with a late submission fee — estimate it with the FEMA late fee calculator.
What is FC-GPR?
FC-GPR is the form an Indian company uses to report to the Reserve Bank of India that it has issued capital instruments — equity shares, CCPS, CCDs or share warrants — to a person resident outside India. It is part of the Single Master Form (SMF) on the RBI’s FIRMS portal and is processed by your Authorised Dealer (AD) bank.
If your startup has raised money from a foreign VC, angel, accelerator or a US / Singapore parent company, FC-GPR is almost certainly required.
When is FC-GPR due?
Two related timelines matter too. Under FEMA, shares must generally be allotted within 60 days of receiving the investment; if not, the money must be refunded within the following 15 days. And every company with foreign investment must file the annual FLA return by 15 July.
Documents you’ll need
- FIRC and KYC of the foreign investor, obtained from the bank that received the funds.
- Board / allotment resolution and the list of allottees.
- Valuation certificate showing the issue price is not below fair value, determined using an internationally accepted pricing methodology on an arm’s-length basis by a Chartered Accountant, SEBI-registered merchant banker or practising cost accountant (for unlisted companies).
- Company Secretary certificate confirming compliance with the Companies Act and FEMA.
- Declaration by the authorised representative, including sectoral cap and entry-route confirmation.
- For convertible instruments, the conversion terms; and where applicable, any government approval.
Step-by-step on the FIRMS portal
- Entity Master registration — make sure your company is registered on FIRMS with an entity user; this is a one-time step and can take time, so do it before the round closes.
- Business user — register the person who will submit forms.
- Prepare the SMF — select FC-GPR, enter investor, instrument, pricing and allotment details exactly as per your documents.
- Upload documents — FIRC, KYC, valuation report, CS certificate and declarations.
- Submit to the AD bank — the bank reviews and may raise queries; respond promptly.
- Acknowledgement — once approved you receive an acknowledgement; keep it in your data room, investors will ask for it.
What if you miss the 30-day deadline?
Late reporting can usually be regularised by paying a Late Submission Fee (LSF). Under the RBI’s current framework the fee is a fixed amount plus a small percentage of the amount involved for each year of delay, and the LSF route is available only within a limited window from the due date. Longer or repeated delays may require compounding of the contravention.
Beyond the fee, a late or incorrect FC-GPR is a red flag in the next round’s due diligence — it’s much cheaper to get it right the first time.
Common mistakes we see
- Counting 30 days from receipt of funds instead of from allotment (or the reverse, for the 60-day allotment rule).
- Valuation report dated after the allotment or based on stale financials.
- FIRC amount not matching the allotment because of bank charges or FX differences — explain the difference upfront.
- Entity Master not set up until after closing, eating most of the 30-day window.
- Forgetting the annual FLA return after the first foreign round.
Need a hand? See FEMA / RBI compliance or the companion guide on FC-TRS for share transfers.
Frequently asked questions
What is the due date for FC-GPR?
Who files FC-GPR?
Is a valuation certificate mandatory for FC-GPR?
What is the penalty for late FC-GPR filing?
Please note: this guide is general information based on the rules as they stood on the review date above. Regulations and RBI/CBDT procedures change often — please get advice on your specific facts before acting.