RBI rejects or queries an FC-GPR filing for five recurring reasons: filing after the 30-day deadline, a valuation or pricing mismatch, the FIRC amount not reconciling with the allotment, wrong or incomplete entity details (including filing FC-GPR when FC-TRS was needed), and missing or defective supporting documents. Every one of these is avoidable by preparing the full document set before you allot shares.
An FC-GPR that bounces back from the AD bank or RBI is not just an administrative nuisance — it restarts the clock, attracts a Late Submission Fee, and leaves a foreign investment unreported on FEMA records. In the filings we handle for venture-backed companies, the same five problems account for nearly every rejection. Here they are, with the fix for each.
1. Filing after the 30-day deadline
FC-GPR must be filed within 30 days of the allotment of shares. The most common rejection trigger is simply missing that window — and the most common cause is a misunderstanding of when the clock starts.
The 30 days run from the date of allotment — the date the board formally allots the shares — not from the date the money hit the bank account. Founders see the wire land and start counting from there; the actual window often opens later, when the board passes the allotment resolution.
How to file it right: do not delink allotment from filing. Schedule the allotment board meeting only once you have the FIRC, KYC and valuation certificate in hand. A late return still has to be filed — with a Late Submission Fee that grows with the delay — so the cost of slipping is real.
2. A valuation or pricing mismatch
FC-GPR filings are checked against FEMA pricing guidelines. A non-resident must not be issued shares below the fair value certified by a registered valuer. Rejections happen when the issue price is below that floor, when the valuation certificate is stale, or when the valuation date does not line up with the allotment.
How to file it right: obtain a valuation certificate from the appropriate registered valuer or merchant banker, dated close to the allotment, and ensure the issue price is at or above the certified fair value. Keep your FEMA valuation and your income-tax valuation (Rule 11UA) consistent — an inconsistency between the two is a frequent query.
3. The FIRC amount does not reconcile with the allotment
RBI expects the foreign money that came in to match the shares that went out. If the FIRC (Foreign Inward Remittance Certificate) shows one figure and the allotment shows a different rupee amount, the return is queried.
The usual culprit is forex conversion difference — the dollar amount converts to a slightly different rupee figure than the founder used — or a partial remittance where only part of the committed amount has arrived.
How to file it right: reconcile the FIRC amount, the bank credit and the allotment value before you file. Allot shares only for the amount actually received and certified on the FIRC. If consideration is arriving in tranches, align each allotment with the remittance it corresponds to.
4. Wrong or incomplete entity details — or the wrong form entirely
FC-GPR pulls company details from the FIRMS Entity Master. If the Entity Master is not registered, is out of date, or carries an incorrect CIN or activity code, the return cannot be validated.
The more serious version of this error is filing FC-GPR when the transaction was actually a transfer. If existing shares moved between a resident and a non-resident, the correct form is FC-TRS, not FC-GPR — see our guide on FC-GPR vs FC-TRS to confirm which applies.
How to file it right: complete and update the Entity Master before filing, verify the CIN and activity details, and confirm the transaction is genuinely a fresh issue of shares before you open an FC-GPR form.
5. Missing or defective supporting documents
FC-GPR requires a specific set of attachments, and a half-prepared upload is how filings get rejected. The recurring defects: a KYC report not issued by the AD bank, a CS certificate not in the prescribed format, a missing board resolution, or a declaration that does not match the data entered on the portal.
How to file it right: assemble the full set before you start — FIRC, AD-bank KYC report, valuation certificate, board resolution, CS certificate and the declaration. Each must be current, correctly formatted and internally consistent with the figures on the form.
The pre-filing checklist that prevents all five
Before you open an FC-GPR form on FIRMS, confirm:
- The board has allotted the shares, and you are inside the 30-day window from that date.
- A valuation certificate supports an issue price at or above fair value.
- The FIRC amount reconciles with the allotment value.
- The Entity Master is registered and up to date, and this is a fresh issue (not a transfer).
- FIRC, KYC, valuation certificate, board resolution, CS certificate and declaration are all in hand and consistent.
For the full procedure, see our step-by-step FC-GPR filing guide.
Frequently asked questions
Why was my FC-GPR rejected on the FIRMS portal?
The most common reasons are filing after the 30-day deadline, an issue price below FEMA fair value, the FIRC amount not reconciling with the allotment, incorrect Entity Master or CIN details, and missing or defective supporting documents such as the AD-bank KYC or CS certificate.
What is the deadline to file FC-GPR?
FC-GPR must be filed within 30 days of the allotment of shares to the non-resident investor. The window runs from the date of the allotment resolution, not from the date the funds were received.
Can I re-file an FC-GPR after it is rejected?
Yes. A queried or rejected return is corrected and re-submitted through the FIRMS portal. If the corrected filing is now beyond 30 days from allotment, a Late Submission Fee will apply.
What happens if I file FC-GPR late?
RBI levies a Late Submission Fee calculated on the amount involved and the length of the delay. The fee increases the longer the return remains unfiled, and the unreported investment can also surface as a compliance flag during investor due diligence.
Do I need a Company Secretary to file FC-GPR?
A practising Company Secretary’s certificate is one of the prescribed attachments for FC-GPR. Many companies also engage a CS to manage the filing because the pricing, reconciliation and documentation requirements are where rejections happen.
Reviewed by CS Sapna Malpani, a practising Company Secretary based in Bangalore who files FEMA and FDI returns for venture-backed companies. This article is general information, not legal advice — confirm the current RBI Master Direction on Reporting under FEMA for your filing. About Sapna Malpani.
Last reviewed: May 2026.