By S&S Co. Advocates & Solicitors · Published 20 September 2026 · Informational content, not legal advice — see our disclaimer
Two Different Forms for Two Different Events
Form FC-GPR reports a fresh issue of capital instruments — shares, convertible debentures and similar instruments — by an Indian company to a person resident outside India, and must be filed within 30 days from the date of allotment, regardless of when funds were actually received. Form FC-TRS instead reports a transfer of capital instruments between a resident and a non-resident, or vice versa, and must be filed within 60 days from the date of transfer or receipt of consideration, whichever is earlier. Getting the right form for the right transaction — fresh issue versus transfer — matters, since filing the wrong form does not satisfy the reporting obligation for the actual transaction that occurred.
The FIRMS Portal and Entity Master Form
Both filings are made through the Foreign Investment Reporting and Management System (FIRMS) portal via the Single Master Form. A one-time Entity Master Form registration, recording the company's CIN, PAN and sector, is a prerequisite before any transaction-based filing can be made — a company that has never registered its Entity Master Form cannot simply jump straight to filing an FC-GPR or FC-TRS for a specific transaction.
Supporting Documents
Required supporting documents typically include the Foreign Inward Remittance Certificate, a KYC report from the remitter's bank, a valuation certificate confirming pricing compliance, and a company secretary certificate confirming compliance with the Companies Act and FEMA pricing guidelines. Assembling these documents in parallel with the underlying investment transaction, rather than only after the fact, materially speeds up the filing process within the applicable deadline.
Consequences of Late or Non-Filing
Late or non-filing exposes the company to compounding proceedings under FEMA, with the option to regularise the position via RBI's compounding application route rather than facing open-ended, indefinite penalty exposure. Companies that discover a missed FC-GPR or FC-TRS filing should treat proactive compounding as the sensible remedial path, rather than continuing to leave the non-compliance unaddressed on the assumption it may not be noticed.
Frequently Asked Questions
When must FC-GPR be filed?
Within 30 days from the date of allotment of capital instruments to a person resident outside India, regardless of when the corresponding funds were actually received.
When must FC-TRS be filed?
Within 60 days from the date of transfer of capital instruments between a resident and a non-resident (or vice versa), or receipt of consideration, whichever is earlier.
What if a company missed a past FC-GPR or FC-TRS filing?
Late or non-filing exposes the company to compounding proceedings under FEMA. RBI's compounding application route lets a company proactively regularise the position rather than leaving the non-compliance unaddressed indefinitely.
References & Further Reading
This article references the following statutory provisions. Readers should always verify current rules, fees and timelines against the applicable statute and rules as amended, since these are revised from time to time.
- Foreign Exchange Management Act, 1999 and FEMA (Non-Debt Instruments) Rules, 2019.
- RBI Master Direction on Reporting under Foreign Exchange Management Act, 1999, and current FIRMS portal procedure.