# FC-GPR, FC-TRS and the FLA return: what is filed on FIRMS, and what is not

By CA Prachi Goel · Updated 2026-10-18 · Source: https://fxlayerhq.com/insights/firms-fcgpr-fctrs-fla

Expert opinion · FEMA reporting

**Short answer.** An Indian company reports equity issued as foreign direct investment in Form FC-GPR within 30 days of issue. A transfer between a resident and a non-resident on a repatriable basis goes in Form FC-TRS within 60 days of the transfer or the funds, whichever is earlier. Both are filed on FIRMS. The annual FLA return is not: it is filed on FLAIR by 15 July.

FIRMS is the portal for the transaction. FLAIR is the portal for the annual balance-sheet return. Mixing the two is the most common reason a filing is described as late when it was sent to the wrong place.

## Key points

- Equity instruments are issued within 60 days of receiving the consideration. If they are not, the money is refunded within 15 days after those 60 days.
- FC-GPR is filed not later than 30 days from the date of issue, where the issue is foreign direct investment.
- FC-TRS is filed within 60 days of the transfer or of the receipt or remittance of funds, whichever is earlier. A sale between a non-resident on a non-repatriable basis and a resident is not reported in FC-TRS.
- The June 2026 amendment of the mode-of-payment regulations changed how certain NRI and international-exchange investments are paid for. It did not, in the text read for this guide, change the 30-day and 60-day reporting periods.
- The FLA return is due on or before 15 July on FLAIR. The regulations still say that. The extension for FY 2025-26 is a separate fact, covered in the FLA guide.

## Issue the shares, then report them

Under the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019, as amended up to 13 June 2026, the consideration for equity instruments under Schedule I is paid as an inward remittance or from a repatriable account. The company issues the instruments within 60 days of receiving the consideration. For partly paid shares, each call payment has its own 60 days. If the instruments are not issued in time, the money is refunded by [outward remittance](https://fxlayerhq.com/insights/form-a1-vs-form-a2) or by credit to the repatriable account within 15 days from the end of those 60 days.

Form FC-GPR then reports the issue. Regulation 4(1) says an Indian company issuing equity instruments to a person resident outside India, where the issue is reckoned as foreign direct investment, reports it in Form FC-GPR not later than 30 days from the date of issue. An issue of participating interest or rights in oil fields is also reported in FC-GPR. RBI's list of returns gives the same 30 days and names FIRMS as the channel.

## Transfers: FC-TRS, and the transfers that are not reported

Form FC-TRS is filed for a transfer of equity instruments between a person resident outside India holding on a repatriable basis and a person resident outside India holding on a non-repatriable basis, and between a person resident outside India holding on a repatriable basis and a person resident in India. The onus is on the resident transferor or transferee, or on the person resident outside India who holds on a non-repatriable basis, as the case may be.

A sale between a person resident outside India holding on a non-repatriable basis and a person resident in India is not reported in Form FC-TRS. A transfer on a recognised stock exchange by a person resident outside India is reported by that person. A transfer under rule 9(6) of the Non-Debt Instrument Rules is reported on every tranche, again with the onus on the resident party. The form is filed within 60 days of the transfer or of the receipt or remittance of funds, whichever is earlier.

The amendment of 13 June 2026, Notification FEMA 395(4)/2026-RB, substituted the mode-of-payment instructions for Schedule III (NRI and OCI investment on a repatriation basis) and Schedule XI (shares listed on an international exchange). The reporting periods for FC-GPR and FC-TRS in regulation 4 were still the 30 days and 60 days above when this guide was checked against the consolidated regulations. Do not assume a later circular has moved them without reading it.

## The FLA return is a different portal

Regulation 4(2) of the same regulations requires an Indian company that has received FDI, or an LLP that has received capital contribution, in the previous year including the current year, to submit the FLA return to the Reserve Bank on or before 15 July. The year is April to March. RBI's list of returns puts that return on FLAIR, not on FIRMS, and describes it as the annual census of foreign liabilities and assets.

Filing FC-GPR does not file the FLA return, and filing the FLA return does not cure a late FC-GPR. The [FLA guide](https://fxlayerhq.com/insights/fla-return) covers who must file, the [extension](https://fxlayerhq.com/insights/export-realisation-timelines) to 31 July 2026 for the year ended 31 March 2026, the 30 September revision, and the sections of the form. This guide does not repeat them.

## Other FIRMS forms, in one line each

The same regulation and RBI's returns list put several neighbours on FIRMS. The periods below are the ones in the consolidated regulations and on that list, checked on 18 October 2026:

- Form ESOP, within 30 days from the issue of the option to a person resident outside India who is an employee or director, including of the holding company or the overseas subsidiary.
- Form LLP (I), within 30 days of receipt of the consideration for capital contribution or profit share. Form LLP (II), within 60 days of receipt of funds on a transfer, with the onus on the resident party.
- Form CN, within 30 days of issue of a convertible note by a start-up, and within 30 days of a transfer.
- Form DI, within 30 days of allotment, for a downstream investment that is indirect foreign investment. The Indian investor also notifies DPIIT within 30 days of the investment, even before allotment.
- Form InVI, within 30 days of the issue of units. Form DRR, by the domestic custodian, within 30 days of the close of an issue of depository receipts.

Regulation 5 says the person responsible for these reports is liable for a late submission fee as decided by the Reserve Bank in consultation with the Central Government. The regulations do not, in the text read here, print the rupee amount of that fee. Use the fee advice the regional office or the FIRMS acknowledgement gives you, rather than a figure from memory.

FC-GPR, FC-TRS and these other forms are filed on FIRMS by the company or the resident party. The FxLayer platform does not file them. The FLA return, which is the annual piece, can be prepared on the platform and is still submitted by the entity on FLAIR.

## Questions

**Is the FLA return filed on FIRMS?**

No. FC-GPR, FC-TRS and the related transaction forms are FIRMS filings. The FLA return is filed on the FLAIR portal.

**How long do we have to issue the shares?**

60 days from receipt of the consideration, under Schedule I of the mode-of-payment regulations. If they are not issued, the money is refunded within 15 days after that.

**Who files FC-TRS?**

The resident transferor or transferee, or the non-resident who holds on a non-repatriable basis, depending on the transfer. A sale by a non-resident holding on a non-repatriable basis to a resident is not reported in FC-TRS.

**Did the June 2026 amendment change the 30-day FC-GPR limit?**

Not in the consolidated regulations read for this guide. That amendment substituted the payment instructions for Schedules III and XI. The FC-GPR period in regulation 4 was still 30 days from the date of issue.

## Sources

- [RBI Notification FEMA 395/2019-RB: Mode of Payment and Reporting of Non-Debt Instruments Regulations, 2019, as amended up to 13 June 2026](https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=11723)
- [RBI: list of returns, including Form APR, FC-GPR, FC-TRS and Form ECB 2](https://rbi.org.in/Scripts/BS_Listofallreturns.aspx?id=2777)
- [RBI Master Direction: Reporting under Foreign Exchange Management Act, 1999 (updated 1 October 2026), including the Annual Return on Foreign Liabilities and Assets](https://www.rbi.org.in/Scripts/BS_ViewMasDirections.aspx?id=10202)
- [RBI FLAIR portal (Foreign Liabilities and Assets Information Reporting), where the FLA return is filed](https://flair.rbi.org.in)

This article is general information on Indian foreign exchange and tax rules as they stood on the date shown. It is not legal or tax advice. Rules and limits change; confirm the current position with your AD bank, the relevant RBI Master Direction or your adviser before acting.