07 November 2026 · Updated 07 November 2026
By Avil Rakshith Salins, Practising Company Secretary
Form FC-GPR: reporting shares issued to a non-resident
In short
An Indian company that issues shares or other equity instruments to a person resident outside India reports the issue to the RBI in Form FC-GPR within 30 days of the allotment. It is filed on the FIRMS portal and reviewed by the company's bank. The shares themselves must be issued within 60 days of receiving the money.
When it is filed
For every issue of equity instruments to a person resident outside India under the FDI route: on incorporation to a foreign subscriber, a fresh or rights allotment, a private placement, or the conversion of a convertible instrument.
Time limit
Within 30 days of the date of issue. The shares must be issued within 60 days of receiving the money; otherwise the money must be refunded.
Where
On the RBI's FIRMS portal, after the company has registered through the Entity Master and has a business user. The company's bank (its AD bank) reviews the report.
Documents usually attached
- The board resolution for the allotment
- A valuation certificate showing the issue price meets the FEMA pricing rules
- A certificate from a company secretary in practice on compliance with the Companies Act and FEMA
- The bank's foreign inward remittance certificate and KYC report on the investor
- The memorandum of association, if asked for
Filed late
The report can still be filed with a late submission fee, which depends on the amount and the period of delay.
The Companies Act side
The same allotment is filed with the Registrar in PAS-3: within 15 days for a private placement and 30 days for other allotments.
Frequently asked questions
Sources
- RBI Master Direction – Reporting under Foreign Exchange Management Act, 1999
- Foreign Exchange Management (Non-debt Instruments) Rules, 2019
General information on the law as on 07 November 2026, not advice on any particular matter. Check the current MCA form and instruction kit before filing.