Who needs to file FC-GPR?

Any Indian company that allots shares (or convertible instruments) to a non-resident. The filing is on the RBI FIRMS portal within 30 days of allotment.

When is the FLA Return due?

Annually, on or before 15 July, by every Indian entity that has received FDI or made ODI — even if there is no transaction in the year.

What penalties apply for FEMA contraventions?

Up to 3x the sum involved (or up to Rs 2 lakh where not quantifiable), plus Rs 5,000/day for continuing default. Most breaches can be regularised via a compounding application with RBI.

Where does FEMA / RBI compliance fit in for foreign founders?

It runs alongside India entry and operations. See the Foreign Founder's Guide for the full picture and the spokes on FDI reporting and profit repatriation.

FEMA • RBI • FDI

Relevant for:For Foreign Companies For NRIs

FEMA and RBI Compliance for Foreign-Owned Indian Entities

FC-GPR, FC-TRS, FLA Return, APR, ODI and ECB filings — drafted, reviewed and filed by our CA team via the FIRMS portal and your AD Bank. Penalty-prevention advisory included. For NRI-specific FEMA and DTAA queries see NRI Blueprint's FEMA & DTAA hub for NRIs.

Get FEMA Compliance Support Back to India Entry

Filings We Handle

FC-GPR

Foreign Currency – Gross Provisional Return

When

Within 30 days of allotment of shares to a non-resident.

Documents

Form FC-GPR on FIRMS portal
Share valuation certificate (CA / Merchant Banker)
Company Secretary certificate
FIRC / debit certificate from AD Bank
Board resolution and list of allottees

FC-TRS

Transfer of Shares — Resident ↔ Non-Resident

When

Within 60 days from the date of receipt / remittance of consideration.

Documents

Form FC-TRS on FIRMS portal
Valuation certificate as per pricing guidelines
Consent letter from buyer and seller
FIRC / outward remittance proof

FLA Return

Foreign Liabilities and Assets Annual Return

When

Annually, on or before 15 July, by every Indian entity that has received FDI or made ODI.

Documents

Audited financials (or unaudited with subsequent revision)
Details of FDI, ODI and outstanding balances

APR

Annual Performance Report — Overseas Direct Investment

When

Annually, by 31 December, for Indian parties holding ODI in JV / WOS abroad.

Documents

Audited financials of the overseas entity
Repatriation and investment details

ODI

Overseas Direct Investment Filings

When

At each remittance and on structural changes (disinvestment, restructuring).

Documents

Form FC (revised ODI forms)
Valuation report
Board resolution and statutory auditor certificate

ECB

External Commercial Borrowings Reporting

When

Form ECB at the loan agreement stage; ECB-2 monthly return by the 7th of the following month.

Documents

Loan agreement and LRN (Loan Registration Number)
Drawdown and repayment schedule
Auditor certificate

FEMA / RBI Compliance Calendar

Due Date / Trigger	Filing
Within 30 days of allotment	FC-GPR
Within 60 days of transfer	FC-TRS
7th of each month	ECB-2 Return
15 July (annually)	FLA Return
31 December (annually)	APR for ODI
Event-based	ODI Form FC, single master form changes

FEMA Penalty Prevention

FEMA contraventions can attract penalties up to 3x the sum involved (or up to ₹2 lakh where the amount is not quantifiable), plus ₹5,000/day for continuing default. We pre-empt common triggers and, where needed, file compounding applications with RBI.