Foreign Founder's Guide

Setting Up in India: The FDI Route, Sectoral Caps & FC-GPR Reporting

Foreign investment into an Indian company comes in under the automatic route (no prior approval, most sectors up to the sectoral cap) or the government approval route (sensitive sectors, and any investor from a country sharing a land border with India). Shares issued to a non-resident must be priced at not less than fair value and reported on Form FC-GPR via the RBI FIRMS portal within 30 days of allotment.

Key takeaways

  • Most sectors permit 100% FDI under the automatic route (no prior approval).
  • Sensitive sectors and any investor from a land-bordering country need government (approval) route.
  • Shares to a non-resident must be issued at not less than fair value, certified by a CA or merchant banker.
  • Report allotment on Form FC-GPR within 30 days via the RBI FIRMS portal.
  • Annual FLA Return is due by 15 July; share transfers between residents and non-residents go on Form FC-TRS.

What is the automatic route vs the government route?

Under the automatic route, a foreign investor does not need prior approval from the Government of India or RBI before bringing capital into an Indian company — the Indian company simply files the post-facto reporting (FC-GPR) on the RBI FIRMS portal.

The government (approval) route applies in two situations: (i) sectors that the FDI policy classifies as sensitive — for example portions of defence, broadcasting, print media, and multi-brand retail; and (ii) under Press Note 3 (2020), any investor that is a resident of — or whose beneficial owner is in — a country sharing a land border with India, irrespective of sector or amount.

What are the sectoral caps for FDI in India?

100% FDI under the automatic route is permitted in most sectors, including IT and software services, manufacturing, e-commerce marketplaces, professional services, and many parts of financial services. Sector-specific caps and conditions continue to apply in areas such as defence, insurance, telecom, private banking, and multi-brand retail. Always confirm the current cap and any conditions for your sector before structuring the round.

At what price can a foreign investor subscribe to shares?

Shares issued to a non-resident must be priced at not less than fair value. That fair value must be certified by a Chartered Accountant or SEBI-registered merchant banker using an internationally accepted valuation methodology — typically Discounted Cash Flow (DCF) for an unlisted company. The same pricing principle applies to transfers: a resident cannot sell shares to a non-resident below fair value, and a non-resident cannot sell to a resident above fair value.

How is the FDI reported?

The Indian company reports the inflow on the RBI FIRMS portal:

  • Form FC-GPR — within 30 days of allotment of shares to a non-resident.
  • Form FC-TRS — for transfer of shares between a resident and a non-resident.
  • Annual FLA Return — Foreign Liabilities and Assets return, due by 15 July every year for any entity that has received FDI or made ODI.

Late FC-GPR, FC-TRS, or FLA filings are common triggers for FEMA contraventions and compounding applications — see FEMA / RBI Compliance.

Which India entry vehicle should a foreign founder choose?

For most operating businesses, a wholly owned subsidiary (WOS) is the cleanest long-term structure — full control, clear ring-fencing, and a straightforward FDI/dividend path. A joint venture makes sense where local relationships, licences, or sector restrictions require an Indian partner. Where you want a presence but not a separate company, look at a branch or liaison office.

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