/ FEMA Form Checklist · Updated 2026-10-22
Form FC-GPR Filing Checklist India 2026, 30-day deadline + checklist.
Form FC-GPR (Foreign Currency - Gross Provisional Return) is mandatory FEMA filing by Indian company receiving foreign inward FDI remittance: within 30 days of share allotment post remittance. Non-filing attracts FEMA Section 13 compounding. Here's the complete 2026 filing checklist.
DC
Written by CA Durgesh Chavda
Chartered Accountant (ICAI) · Founder, Bharat Quantum Prospera · US incorporation, India-US DTAA, FEMA ODI, NRI taxation, cross-border structuring · LinkedIn
/ Who must file + when
The core rule.
- Indian company receives foreign inward remittance for share subscription (FDI).
- Share allotment made to foreign subscriber.
- Form FC-GPR filed within 30 days of allotment via FIRMS portal (RBI).
- Non-filing or late filing: FEMA Section 13 compounding (voluntary) or RBI inspection + penalty up to 3x amount involved.
/ Required documents
The attachments.
- FIRC (Foreign Inward Remittance Certificate) from AD bank.
- KYC of foreign subscriber (passport + address proof).
- Board resolution authorising allotment.
- Share allotment letter.
- Pricing certification: CA / Merchant Banker certificate confirming price per Rule 21 Pricing Guidelines (DCF for unlisted; closing price for listed).
- Non-resident declaration of eligibility.
- CS certificate of compliance (where applicable).
/ Filing workflow
Step-by-step.
- Collect foreign shareholder KYC + apostilled documents pre-allotment.
- Verify FDI route: automatic vs approval; sector cap check.
- Press Note 3 beneficial ownership check for land-bordering country investments.
- Receive foreign remittance in AD-I bank account. Obtain FIRC.
- Allot shares via board resolution within 60 days of remittance (Rule 2A Companies Act).
- Issue share certificates + file Form PAS-3 within 30 days.
- Obtain pricing certificate from CA / Merchant Banker.
- File Form FC-GPR via FIRMS portal within 30 days of allotment.
- AD bank reviews + confirms successful filing.
- Preserve filing acknowledgement + all supporting documents 8+ years.
/ Common mistakes + fixes
What goes wrong.
- Missed 30-day deadline: FEMA compounding under Section 13 - INR 10,000-50,000 per instance typically.
- Pricing below Rule 21 guidelines: FEMA breach - compounding + possible unwinding.
- Press Note 3 breach: beneficial ownership from land-bordering country without approval - serious compounding + unwinding risk.
- Share allotment delay beyond 60 days: separate FEMA breach (Rule 2A pre-amendment was 180 days; now 60 days).
- FIRC not obtained: cannot file FC-GPR without FIRC. Chase AD bank.
- Wrong pricing method: unlisted uses DCF (Rule 21); listed uses closing price. Methodology must match Rule 21.
Last updated: 2026-10-22.
/ Ready when you are
Foreign FDI received? FC-GPR due in 30 days.
FIRC + Rule 21 pricing + FIRMS portal filing. BQP end-to-end + FEMA compounding if past breaches. Scope-based engagement.
FAQ
Common questions, answered.
When is Form FC-GPR due?
Within 30 days of share allotment to foreign subscriber. Allotment itself must be within 60 days of remittance receipt (Rule 2A Companies Act). So typical timeline: remittance → 60 days → allotment → 30 days → FC-GPR filing. Total 90 days from remittance to FC-GPR.
What's the penalty for late FC-GPR?
FEMA Section 13 compounding (voluntary): typically INR 10,000-50,000 per instance for minor delay. For prolonged non-filing or sector-cap breach: significantly higher, up to 3x amount involved. Voluntary compounding is cheaper than RBI inspection-driven proceedings.
What's Rule 21 pricing guidelines?
FEMA Rule 21 (Non-debt Instrument Rules 2019 + predecessors): share issue to non-resident must be at fair value. Unlisted: DCF method (discounted cash flow) by Merchant Banker or Chartered Accountant. Listed: closing price. Issue below Rule 21 pricing is FEMA breach.
Can BQP file FC-GPR for Indian subsidiary of foreign parent?
Yes - standard service. Documentation collection + pricing certification + FIRMS portal filing within 30-day deadline. Also handle associated compliances: Form PAS-3 share allotment + MGT-14 board resolution + FEMA compounding if past breaches.
Does BQP handle FEMA voluntary compounding for missed FC-GPR?
Yes - integrated. Historical FEMA breach audit + Section 13 compounding application + hearing representation + fee payment + closure certificate. See our FEMA compounding guide. WhatsApp +91 78018 87130.
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