FC-GPR, FC-TRS, FLA and APR: FEMA Filing Deadlines Guide

Each FEMA reporting form corresponds to a specific event: FC-GPR within 30 days of issuing shares to a non-resident, FC-TRS within 60 days of a transfer between resident and non-resident, FLA annually by 15 July, and APR annually by 31 December. Late filing is a contravention, regularised through Late Submission Fee or compounding.

FC-GPR — issue of shares to a non-resident

Filed by the Indian company within 30 days of allotting shares, convertible debentures or other eligible instruments to a person resident outside India.

Supporting documents typically include the valuation certificate, the authorised dealer’s confirmation of receipt of funds, board and shareholder resolutions, and a company secretary’s certificate.

The deadline runs from the date of allotment. Delay in filing does not extend the deadline for allotment — the two obligations are independent.

FC-TRS — transfer of shares

Filed within 60 days of receipt or payment of funds, or execution of the transfer deed, whichever occurs first. Applies to transfers between a resident and a non-resident in either direction.

Pricing must respect the valuation floor or ceiling depending on the direction of transfer.

FLA — annual return on foreign liabilities and assets

Due by 15 July each year, filed by every Indian entity that has received FDI or made overseas investment, based on holdings as at the financial year end.

Two common errors: assuming it is not required in a year with no transactions, and filing on unaudited figures without subsequently revising once accounts are audited.

APR — annual performance report

Due by 31 December, filed in respect of overseas direct investment, reporting the performance of the overseas entity. Required annually while the investment subsists.

Failure to file the APR can restrict further overseas investment by the same entity, making it a commercial constraint as well as a compliance one.

ECB-2 — external commercial borrowings

Monthly return due within 7 days of the close of each month, continuing for the entire life of the loan.

Other filings

Form ESOP within 30 days of allotment to non-resident employees. Downstream investment reporting where a foreign-owned or controlled Indian company invests in another Indian entity.

Missing a deadline

Late Submission Fees accrue daily. Filings cannot be regularised through LSF beyond three years, at which point compounding becomes mandatory.

The practical guidance is to disclose voluntarily rather than wait for detection, since delay increases the cost — duration is a factor in both LSF and compounding computation.

Related reading

• the FDI compliance sequence — FEMA Compliance Checklist for FDI in India
• late filing and compounding — FEMA Contraventions and RBI Compounding: What Triggers Action
• the annual calendar — Compliance Calendar FY 2026-27: Income Tax, GST, FEMA and ROC

Sources

• RBI Master Direction — Reporting under FEMA — rbi.org.in