FC GPR and FC TRS reporting

Identify the event and parties

Record the issuer, investor, transferor and transferee as relevant, their residence status, instrument and transaction dates. Distinguish a subscription from a secondary transfer, conversion or another event. A foreign remittance alone does not identify the correct form.

RBI’s non-debt-instrument reporting regulations describe FC-GPR for qualifying issues by Indian companies and FC-TRS for specified transfers. Review exclusions and special cases, including repatriation basis and the instrument involved, before treating every resident/non-resident transaction alike.

Establish the reporting clock

For the qualifying issue described in the regulations, FC-GPR is due within thirty days from issue of the equity instruments. Keep the issue date and supporting corporate record distinct from the receipt date. Review the operative provisions for the actual event and period.

For a transfer, identify the applicable reporting trigger, consideration dates and any tranche or deferred-payment arrangement from the current rules. Assign the responsible filer expressly. Do not substitute a generic closing date for a trigger that depends on different facts.

Prepare the issue file

• Subscription terms, instrument details and investor identification.
• Receipt evidence and bank KYC or other required confirmations.
• Valuation and the basis for the issue price where required.
• Corporate approvals, allotment evidence and updated capital records.
• Pre- and post-issue shareholding and relevant declarations.
• Investment route, sector conditions and approval evidence where applicable.

Prepare the transfer file

• Transfer agreement, parties and residence status.
• Instrument quantity, consideration and payment schedule.
• Valuation or pricing support and applicable declarations.
• Evidence of transfer and updated ownership records.
• Payment or remittance evidence matched to the consideration.
• Any approval, special condition or exception supporting the transaction.

Reconcile before using FIRMS

Check that names, amounts, dates and instrument quantities agree across the bank records, agreements, corporate filings and share register. Explain exchange differences and partial payments instead of forcing inconsistent figures to match.

For example, an investor pays in two instalments but the company issues instruments in one allotment. Preserve both receipt dates and the allotment record, and assess the reporting and issue requirements from that chronology. Do not invent one receipt date for convenience.

Track the filing through queries

Use the authorised FIRMS/Single Master Form workflow with correct entity and user details. Retain the submitted form, attachments and acknowledgement. RBI’s FIRMS portal directs applicants to their authorised dealer bank as the first contact for queries.

Respond to returned or clarification items with a versioned record of changes. A saved draft, submission reference and completed processing status are different stages. Keep the final status and supporting communication in the transaction file.

Separate reporting from transaction validity

Reporting does not replace the review of sector restrictions, pricing, instrument eligibility or required approvals. Assess a delayed filing through the applicable regularisation process; payment of a reporting fee should not be assumed to cure every substantive contravention.

Update the investment register and assess annual FLA and other follow-on obligations separately. Bring the complete chronology, agreements, valuation, bank records and corporate evidence to Kosha.Services for a coordinated reporting checklist and reconciliation.