Engagement
FEMA and RBI filings for companies in Bengaluru
Last reviewed 07 November 2026
FC-GPR, FC-TRS, the FLA return and late submission fees.
In short
An Indian company that receives foreign investment reports it to the RBI under FEMA through its bank on the FIRMS portal: FC-GPR within 30 days of issuing shares to a non-resident, FC-TRS within 60 days when shares move between a resident and a non-resident, and the FLA return by 15 July every year while the investment is on its books. A missed report can be regularised with a late submission fee.
Overview
Foreign investment into an Indian company is governed by the Foreign Exchange Management Act, 1999, the Foreign Exchange Management (Non-debt Instruments) Rules, 2019 and the RBI's Master Direction on reporting under FEMA. Most reports are filed online on the RBI's FIRMS portal and reviewed by the company's bank (its AD bank).
The company first registers on FIRMS through the Entity Master. Each issue of shares to a non-resident is then reported in FC-GPR within 30 days, and each transfer of shares between a resident and a non-resident in FC-TRS within 60 days of the transfer or receipt of funds, whichever is earlier. Every year, by 15 July, a company or LLP with foreign investment outstanding files the FLA return.
The same transaction also has a Companies Act side: the allotment in PAS-3, any special resolution in MGT-14, and share certificates or a demat credit. The practice runs both sides on one timetable, so that the RBI report and the ROC filing describe the same allotment.
The filings
| Report | When it is filed | Who files |
|---|---|---|
| Entity Master registration | When it is filed: Once, before the first FIRMS report | Who files: The company |
| FC-GPR | When it is filed: Within 30 days of issuing shares to a non-resident | Who files: The company |
| FC-TRS | When it is filed: Within 60 days of the transfer or receipt of funds, whichever is earlier | Who files: The resident party to the transfer |
| Form DI (downstream investment) | When it is filed: Within 30 days of the investment | Who files: The Indian company making it |
| FLA return | When it is filed: By 15 July every year | Who files: Companies and LLPs with foreign investment outstanding |
Guides: Form FC-GPR and the FLA return. For a foreign-owned company's full year, see compliance for Indian subsidiaries of foreign companies.
Key Deliverables
- Entity Master and business user registration on FIRMS
- FC-GPR with the board resolution, valuation certificate, company secretary's certificate and the bank's KYC report
- FC-TRS for transfers between residents and non-residents
- The FLA return every July
- Late submission fee applications for reports that were missed
- The Companies Act side of the same transaction: PAS-3, MGT-14, share certificates or demat credit
Documents & E-Forms
- FC-GPR
- FC-TRS
- FLA
- Form DI
- PAS-3
When to Engage
Before the foreign money arrives, so that the allotment, its FEMA report and the Companies Act filings run on one timetable.
Typical turnaround: Scoped in the engagement letter.
Frequently Asked
About this engagement
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