FDI Filing with RBI Online – Expert Compliance by Vijendra & Co

Through capital infusion, job creation, and innovation promotion, foreign direct investment (FDI) is essential to bolstering India's economic structure. However, it comes with a series of compliance obligations, especially with respect to reporting requirements to the Reserve Bank of India (RBI). FDI Filing with RBI Online is one such critical process, and at Vijendra & Co, we specialize in simplifying it for businesses, startups, and investors across India.

Overview of FDI Filing with the RBI

For Indian businesses that receive foreign investment, filing an FDI with the RBI is a must. The filing ensures that the inflow of foreign capital is within the regulatory framework of the Foreign Exchange Management Act (FEMA), 1999. Any delay or error in FDI reporting can attract severe penalties, making it crucial for companies to handle it with precision.

FDI filing with RBI is primarily done through the Single Master Form (SMF) on the FIRMS portal, which includes various sub-forms such as FC-GPR, FC-TRS, LLP-I, LLP-II, CN, ESOP, DRR, and DI.

The Reason for Filing FDI Reports with the RBI

FDI reporting's primary goals include:

• Monitoring and tracking the foreign capital inflow into India.
• Ensuring compliance with sectoral caps and conditions prescribed under FDI policy.
• Enabling the government and RBI to assess macroeconomic trends.
• Stopping illegal operations like foreign exchange violations and money laundering.

Maintaining investor trust in the Indian financial system depends on accountability and transparency, all of which are enhanced by filing FDI through RBI Online.

The Foreign Exchange Management (Non-Debt Instruments) Rules, 2019 and the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019 control applicable regulations on FDI filing with the RBI. These regulations are framed under FEMA, 1999 and are periodically updated to match evolving economic and policy frameworks.

RBI, through the FIRMS (Foreign Investment Reporting and Management System) portal, mandates Indian companies to report any foreign investment transaction via relevant forms, mainly FC-GPR or FC-TRS.

Prerequisites for FDI (Foreign Direct Investment)

Not every foreign investment is immediately permitted. The following general requirements must be fulfilled:

• The investment should fall under the automatic or approval route as per the FDI policy.
• Sectoral caps and entry conditions must be fulfilled.
• The remittance must come through proper banking channels.
• The foreign investor must comply with Know Your Customer (KYC) norms.
• The Companies Act of 2013 and other relevant laws must be followed while issuing the shares or securities.

Understanding these conditions is essential before proceeding with FDI Filing with RBI Online.

FC-GPR Form for FDI Filing

The main form for reporting foreign investment in an Indian company is the FC-GPR (Foreign Currency – Gross Provisional Return). This form needs to be filed when an Indian company issues equity shares or compulsorily convertible instruments to a person resident outside India against FDI received.

When Is the FC-GPR Form Required To Be Filed?

Form FC-GPR must be filed when:

• A company receives FDI through inward remittance or via NRE/FCNR account.
• Shares or convertible securities are allotted to a foreign investor.

The form must be submitted after the shares are allotted, not at the time of receiving funds.

Due Date for Filing Form FC-GPR

Within 30 days of the securities being issued to the foreign investor, the Form FC-GPR needs to be submitted. In order to prevent fines and guarantee regulatory compliance, timely submission is crucial.

Documents Needed to File an FDI with the RBI

In general, the following paperwork is needed to finish the FDI filing process with RBI Online using Form FC-GPR:

• Board Resolution approving the allotment of shares.
• KYC report from the remitting bank.
• FIRC (Foreign Inward Remittance Certificate).
• Acknowledgment of receipt of funds from AD bank.
• CS Certificate certifying compliance with Companies Act and FDI policy.
• Valuation certificate from a SEBI-registered merchant banker or a chartered accountant.
• Declaration made by the company's authorized representative.
• Articles of Association (AOA) and Memorandum of Association (MOA).
• Relevant share certificates and covering letter.

Penalty for Non-Filing of Form FC-GPR with RBI

Non-compliance with FDI reporting timelines can attract heavy penalties under FEMA. The penalty can extend to three times the amount involved or up to ?2 lakh per contravention, along with a daily fine for continued default. Additionally, the investor or the company may face restrictions on future foreign investments.

Process for Filing FC-GPR – Step-by-Step Guide

Here’s a simplified breakdown of the FDI Filing with RBI Online process through Form FC-GPR:

• Step 1: Registration on FIRMS Portal
  The Indian company must register on the FIRMS portal by creating an Entity User account. Login credentials will be issued by the RBI after verification.
• Step 2: Business User Creation
  Once the Entity User is approved, the company can add a Business User authorized to file FDI-related forms.
• Step 3: Fund Receipt and Share Allotment
  The company receives foreign investment in its bank account and conducts a board meeting to approve the allotment of shares or securities.
• Step 4: Preparation of Documents
  All required documents are gathered, including KYC, FIRC, and valuation reports. A practicing Company Secretary prepares the required certificates.
• Step 5: Filing Form FC-GPR
  Log in to the FIRMS portal, fill in the FC-GPR form with transaction and shareholder details, and attach the required documents.
• Step 6: RBI Acknowledgement
  RBI or the Authorized Dealer Bank verifies the submission. Upon approval, the transaction is officially recorded as per FEMA norms.

Simplify Your FDI Filing with CS Vijendra & Co

At Vijendra & Co, we bring deep domain knowledge and procedural expertise to handle the complexities of FDI Filing with RBI Online. Our team of Company Secretaries, Chartered Accountants, and legal experts ensures error-free compliance, timely submissions, and strategic guidance tailored to your business needs.

We simplify end-to-end FDI compliance — from documentation and valuation coordination to precise filing and liaison with banks and regulators. Whether you’re a startup raising foreign funds or a multinational entering the Indian market, our personalized approach ensures your FDI transactions are seamless and penalty-free.