Form FC-GPR within 30 days of share allotment to foreign investors. Form FC-TRS within 60 days of any resident, non-resident share transfer. Filed via the FIRMS SMF portal, routed through your AD bank, no rejections, no LSF.
Four sequential stages from share allotment to AD bank approval. The 30-day FC-GPR clock starts at allotment, not at fund receipt. Most rejections come from skipping the prep work.
Form FC-GPR (Foreign Currency, Gross Provisional Return) is the statutory RBI filing that an Indian company makes within 30 days of allotting capital instruments (equity shares, CCPS, CCDs, warrants) to a person resident outside India against foreign investment received. It is the single most consequential FEMA filing a startup will make in its lifetime, because it permanently records the foreign investment with RBI and forms the basis for every subsequent FC-TRS, repatriation, and exit.
FC-GPR is filed through the Single Master Form (SMF) on the FIRMS portal, routed through your Authorised Dealer (AD) bank. The AD bank does the substantive verification, KYC, valuation, FIRC, sectoral and pricing compliance, and either approves or rejects the filing within 5 working days. Rejected filings cannot be edited; the entire form has to be refiled from scratch under a new SRN.
Form FC-TRS is the counterpart for share transfers (not fresh issuances) between a resident and a non-resident, in either direction. Filed within 60 days of transfer execution or fund receipt, whichever is earlier. Same FIRMS portal, same AD bank routing, same documentation discipline. FC-TRS is not required for non-resident-to-non-resident transfers or pure resident-to-resident transfers.
The FC-GPR / FC-TRS process is unforgiving in three ways. One: rejections require full refiling, no modification path. Two: documents that don't reconcile (KYC name vs FIRC name vs board resolution vs share certificate) almost always cause AD bank rejection. Three: the valuation report must be dated within 90 days of allotment, or RBI flags the filing. Late filings attract Late Submission Fee (LSF) calculated as ₹7,500 + (0.025% × transaction amount × days delayed), capped at the transaction amount; beyond 3 years, full compounding via PRAVAAH is required, much more expensive.
Six activities per transaction. From valuation through AD bank approval, every step we handle so first-time filing succeeds.
FC-GPR is one of the most rejection-prone FEMA filings. Here's when professional handling pays for itself and when in-house is workable.
Six commitments. One dedicated CA across FC-GPR and FC-TRS workflows for every transaction.
The rejection patterns we see most often, and the LSF math when filings slip. Both are avoidable with first-time accuracy.
Talk to a CA in 15 minutes. Response within 30 mins during business hours.
We reply within an hour during business hours. No deck, no sales pitch.