Services for clients across India. Applicable state, sector and professional requirements are assessed before an engagement.
Foreign money into an Indian company triggers a reporting clock the moment shares are allotted: FC-GPR within 30 days, at a price the valuation must support, through an AD bank that will check every annexure. Miss the window and the cure is late submission fees and explanations that follow the company around.
When this service is typically required
- A foreign investor is subscribing to shares or convertibles
- Allotment happened and the 30-day FC-GPR window is running
- Share transfers between residents and non-residents need FC-TRS
- Past reporting gaps surfaced in diligence or bank checks
Indicative scope
- Entity-master and portal readiness on the RBI reporting system
- FC-GPR preparation with valuation, KYC and declarations
- FC-TRS for secondary transfers with pricing evidence
- AD-bank coordination through acknowledgement
- Late-reporting regularisation with LSF workings where windows were missed
Key points at a glance
| Item | Position |
|---|---|
| FC-GPR | Within 30 days of allotment to a non-resident |
| FC-TRS | On resident↔non-resident transfers, within its prescribed window |
| Pricing | Guideline valuation evidence accompanies the filing |
| Late filings | Late Submission Fee framework applies — quantifiable, not negotiable |
Deliverables
Filed forms with acknowledgements, the annexure set (valuation, KYC, declarations, board papers), and a reporting log every future round builds on.
Information and documents generally required
Allotment/transfer documents, FIRC/KYC from the AD bank, valuation certificate, investor details, and past filings for continuity.
Engagement process
Client responsibilities, assumptions and reliance
Investor-side documents (KYC, remittance trails) arrive through their bank — start the chase on day one; the 30-day clock has no patience for time zones.
Scope exclusions
FDI policy structuring (sectoral caps/approval-route questions handled as advisory before the transaction), and compounding proceedings for old contraventions.
Frequently asked questions
The 30 days passed. Options?
Late filing with the Late Submission Fee — computed, paid, documented. It is a cure, not a catastrophe, if handled promptly; layered delays are what escalate matters.
Do SAFEs/convertibles need reporting?
Instruments and structures vary — the readiness step maps exactly which filings your instrument triggers and when, before money moves.
Which valuation does the bank want?
The guideline-consistent certificate — issued under the FEMA valuation scope and attached here so the two never diverge.
Can filings run parallel with the ROC's PAS-3?
They must — the calendars overlap by design in this engagement so neither regulator waits.
The applicable scope, documentation, professional responsibilities and timelines are agreed in an engagement letter before commencement.
FEMA ValuationAllotment & PAS-3Annual FLA ReturnRequest a Scope DiscussionThis page describes the service in general terms as on 6 August 2026 and is not professional advice or an assurance of any outcome. Registrations, filings, refunds and departmental outcomes depend on facts and the concerned authority. Figures and due dates change; verify current positions before acting.
| Compliance | Due | Note |
|---|---|---|
| FLA return (RBI) | 15 July (annual) | All entities with FDI/ODI on books |
| FC-GPR | 30 days from allotment | For fresh foreign investment |
| Valuation report (Rule 11UA / FEMA) | Before issue price is fixed | Method and valuer depend on route |
| ESOP: board/valuation/PAS-3 chain | Event-based | Perquisite TDS on exercise |
| DPIIT recognition | Anytime (before benefits) | Needed for 80-IAC and angel-tax relief |
Dates as generally applicable on 15 July 2026; extensions/notifications can change them — confirm current dates before relying.