India continues to be one of the top destinations for global foreign direct investment. However, cross-border equity infusions and debt instruments must comply strictly with the Foreign Exchange Management Act (FEMA), 1999 and the master directions issued by the Reserve Bank of India (RBI).
Crucial Reporting Timelines on the FIRMS Portal
Foreign inflows into Indian entities trigger strict statutory reporting windows on the RBI’s FIRMS (Foreign Investment Reporting and Management System) portal:
- Entity Master Filing: Initial onboarding of the Indian company on the FIRMS portal prior to foreign investment reporting.
- Form FC-GPR (Foreign Collaboration – General Permission Route): Must be filed within 30 days from the date of allotment of equity shares or convertible instruments.
- Valuation Certificate: Issuance of shares to a non-resident must comply with the arm’s length pricing guidelines, certified by a SEBI-registered Merchant Banker or Practising Chartered Accountant.
- Annual Return on Foreign Liabilities and Assets (FLA): Mandatory annual disclosure submitted by July 15 every year on the RBI FLAIR portal.
