Entity Master registration, Single Master Form (SMF), the strict 30-day allotment window, document requirements, and Late Submission Fee (LSF) mechanisms explained.
Under paragraph 9(1)(A) of Schedule 1 to Notification No. FEMA 20(R)/2017-RB, an Indian company issuing capital instruments to a person resident outside India must report the issue in Form FC-GPR within 30 days from the date of share allotment on the RBI FIRMS (Foreign Investment Reporting and Management System) portal.
Before filing FC-GPR, the company must register its Entity Master on the FIRMS portal. This requires an official authorization letter on company letterhead naming an Entity User, accompanied by board resolution and CIN details. For Kerala entities, approval is verified by the AD Bank and routed to the RBI Regional Office at Kochi.
Log in as the Business User to file Form FC-GPR under the Single Master Form (SMF) tab within the 30-day window following share allotment.
Under RBI circulars, delayed FC-GPR filings can be regularized by paying a matrix-based Late Submission Fee (LSF) to the Reserve Bank of India. Filing late with LSF is vastly preferable to leaving FDI unrecorded, which creates severe title flaws during due diligence, banking reviews, or profit repatriation.
Our FEMA practice handles Entity Master setup, FIRC/KYC liaison with AD banks, CS certification, and FC-GPR filings on the FIRMS portal.
