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What is FC-GPR? Foreign money, a 30-day clock, and the RBI
N° 06 of 14 · 4 min read
The foreign-investment paper trail
- Before anything
- Entity Master registration on the FIRMS portal
- Money arrives
- Issue instruments within 60 days (else refund in 15)
- Shares allotted
- FC-GPR on FIRMS within 30 days
- Filed late
- Late Submission Fee regime — the delay itself has a price
The moment a person resident outside India is allotted shares in your company, the RBI wants to know. Form FC-GPR, filed on the FIRMS portal within 30 days of allotment, is how it finds out.
The pack is where founders lose time: the FIRC (the bank’s certificate of the inward remittance), a KYC report on the remitter from the AD bank, a valuation certificate (the issue price must not be below the certified fair value, computed by an internationally accepted methodology), a company-secretary certificate, board resolutions, and shareholding patterns before and after. Chasing your bank for the FIRC is routinely the slowest step — start early.
Two clocks run in parallel that people confuse: instruments must be ISSUED within 60 days of the money arriving (or refunded within 15 days), and the FC-GPR must be FILED within 30 days of the allotment. And none of it can be filed at all until the company exists in the RBI’s Entity Master — a one-time registration founders discover at the deadline.
Missing the 30 days is not fatal, but it is priced: the RBI’s Late Submission Fee regime applies, and the delay becomes a permanent part of your FEMA record — the kind of thing that surfaces in a later round’s diligence.
The filings clock, tracking statutory deadlines like the ones covered in this explainer.
This explainer is general information, not legal or tax advice. Statutes change and facts differ — confirm decisions with a practising CS/CA.
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