Received foreign investment? Your FC-GPR checklist
When an Indian company issues shares to a foreign investor, it must report that investment to the Reserve Bank of India within a set timeline. The reporting is done in Form FC-GPR through the RBI’s online portal. Get it right and on time, and the investment is cleanly on record; miss the window and you may face a compounding process. Here is what you need.
When FC-GPR is triggered
FC-GPR reporting applies when an Indian company issues equity instruments (such as equity shares, compulsorily convertible preference shares or compulsorily convertible debentures) to a person resident outside India against foreign investment. It is the company’s responsibility to file.
The documents you will typically need
- A valuation certificate supporting the issue price, from an authorised professional.
- The FIRC (Foreign Inward Remittance Certificate) evidencing receipt of funds.
- A KYC report on the foreign investor from the remitting/receiving bank.
- Board and shareholder resolutions authorising the issue and allotment.
- A declaration that the investment complies with the FDI policy and pricing guidelines.
- Details of the equity instruments issued and the allotment.
The timeline
FC-GPR is generally required to be filed within 30 days of the allotment of the shares. Reporting is done through the Single Master Form (SMF) on the RBI’s FIRMS portal. Because the form draws on several supporting documents, it is best to assemble them in parallel with the allotment rather than afterwards.
Common mistakes that cause delays
- Allotting shares before the inward remittance is properly identified and documented.
- A valuation that does not meet the pricing guidelines.
- Missing or mismatched KYC details for the investor.
- Leaving the filing to the last few days of the 30-day window.
Note: FEMA requirements change from time to time and depend on the specifics of your transaction. Confirm the current position for your case. Akash & Co. can manage the end-to-end reporting for you.