Detailed Guide to FC-GPR and FC-TRS Filings
A closer look at when FC-GPR applies versus FC-TRS, the documents each one needs, and how the RBI’s FIRMS portal filing actually runs.
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Two forms, two sides of the same cross-border transaction
FC-GPR reports the allotment of shares or securities to a foreign investor when an Indian company receives fresh foreign investment. FC-TRS reports the transfer of existing shares between a resident and a non-resident, in either direction. Both are filed with the RBI under FEMA, on the FIRMS portal, and both are triggered by a specific transaction date.
Filing the wrong one, or filing it after the window that FEMA sets, is treated as a contravention. Getting the classification right at the outset avoids both problems.
- FC-GPR — fresh shares allotted against inbound FDI
- FC-TRS — existing shares transferred, resident to non-resident or the reverse
- Both filed on the RBI’s FIRMS portal under FEMA
- Both need a valuation certificate and KYC on the foreign party
It depends on what actually happened
Companies issuing new shares
An Indian company allotting shares or convertible securities to a foreign investor against a fresh inflow of funds files FC-GPR.
Parties to a share transfer
Whoever is party to a transfer of existing shares between a resident and a non-resident, in either direction, needs FC-TRS filed for that transaction.
Companies raising rounds with secondary sales
A funding round that combines a fresh allotment with a secondary share sale can need both forms filed for the same transaction.
From documentation to filed acknowledgement
Classification
We confirm which form your transaction needs before any documentation work starts.
Valuation certificate
Coordinating the valuation report your CA or a SEBI-registered merchant banker needs to sign off.
KYC and FIRC
Getting the foreign investor’s KYC report and the Foreign Inward Remittance Certificate in place.
Resolutions and consents
Board resolutions for FC-GPR, or consent letters and the transfer agreement for FC-TRS.
FIRMS portal filing
We prepare and submit the correct form directly on the RBI’s FIRMS portal.
Deadline tracking and queries
We track your specific filing window from the transaction date and respond to any RBI query until the filing is accepted.
Four steps from transaction to filing
We classify
Confirm whether the transaction needs FC-GPR, FC-TRS, or both.
Documents assembled
Valuation, KYC, FIRC and the relevant resolutions or agreements, gathered in one pass.
We file on FIRMS
Submitted on the RBI’s portal, within your transaction’s specific window.
You get acknowledgement
Filed confirmation on record, and any RBI query handled through to closure.
Questions companies ask first.
How do I know whether my transaction needs FC-GPR or FC-TRS?
FC-GPR applies when your company allots new shares against fresh foreign investment. FC-TRS applies when existing shares change hands between a resident and a non-resident. Some funding rounds need both. We classify the transaction before we prepare anything.
What documents does RBI expect for these filings?
A valuation certificate is common to both. FC-GPR also needs the Foreign Inward Remittance Certificate and KYC on the investor; FC-TRS needs the transfer agreement, consent letters and KYC on the non-resident party.
What if the filing is delayed past its window?
A late or missed FC-GPR or FC-TRS filing is treated as a FEMA contravention and can attract penalties, plus complications for a future fundraise or share transfer. We track your transaction’s specific window and file within it.
Tell us what you need.
A short call to understand where you stand and how we would run this for you. No obligation.
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