FIRMS Portal explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Every Indian company or LLP receiving foreign investment must register on the FIRMS portal in two steps — entity user registration verified by the RBI, and business user registration verified by the AD bank branch. The Entity Master then records capital on a fully diluted basis.
Who must register on the FIRMS portal
The RBI has moved filing online through the FIRMS portal at firms.rbi.org.in. Each Indian entity — company or LLP — is required to get registered where it is in receipt of foreign inward remittance as investment in equity instruments in an Indian company or capital contribution in a limited liability partnership.
Registration proceeds in two steps, and they are not alternatives:
- Entity User registration — for the entity which has received foreign investment, required to provide details of foreign investment, including indirect foreign investment, in the Entity Master.
- Business User registration — for the one who would be making filings in the Single Master Form.
The difference matters when deciding who in a group or a professional firm does the filing. "Entity user credentials are entity specific" — one per entity, held by the entity.
Business user credentials "can be obtained by any individual or entity who is required to make filing in SMF" — that is, a chartered accountant, a company secretary or a group compliance team can hold business user credentials and file for the entity.
So the FIRMS portal is designed for the entity to own its master record and for an adviser to do the transactional filings. The forms a business user can file are listed exhaustively: FC-GPR, FC-TRS, LLP-I, LLP-II, CN, DRR, DI, ESOP and InVi.
Entity user registration on the FIRMS portal
The prerequisite is an authority letter in the specified format. The registrant clicks Registration form for New Entity User and completes: first, middle and last name; a unique user name of alphabets and numerics; a valid email, to which the default password will be sent; the PAN of the user, not of the company; a valid ten-digit mobile number; the entity name as per the certificate of incorporation; the entity type — company, LLP or start-up; and the CIN or LLPIN.
Where the company has no CIN, the handbook gives a dummy CIN convention: D12345, the first two letters of the State of the registered office, 2010, the first three letters of the company's name, and 123456.
On submission, the message "Record Saved Successfully" confirms the user ID. The authority letter is then verified by the RBI, and on approval the password arrives from autoreply-fid@rbi.org.in. The handbook adds a practical note: if no notification arrives within 48 hours, contact helpfirms@rbi.org.in.
The four tabs of the Entity Master on the FIRMS portal
| Tab | What goes in it |
|---|---|
| 1. Entity Details | Name and CIN or LLPIN auto-populated; date of incorporation as in the certificate, which cannot be a future date; PAN of the entity; any RBI registration number from earlier allotment reporting; and whether the entity is under investigation by the Directorate of Enforcement, CBI or any other agency for violation of FEMA, 1999 |
| 2. Particulars | Registered office address as in the certificate of incorporation, or as in Form INC-22 if changed; pincode; mobile of the authorised person — director or company secretary; telephone with STD code; entity email; the NIC code of the main activity for which foreign investment is received; and whether greenfield or brownfield |
| 3. Foreign Investment in the Company or LLP | Paid-up capital on a fully diluted basis, or total capital contribution for an LLP; foreign portfolio investment with the FPI, NRI and others split; foreign investment; and indirect foreign investment. The handbook adds: do not report Indian shareholding in this tab |
| 4. Foreign Investment Info | Details of each issue or transfer, not investor-wise — date, description (rights, bonus, share swap, merger, demerger, ESOP, NR to R or R to NR transfer), instrument type, and the number of instruments or percentage of capital contribution |
Submission is gated: only after the declaration checkbox is ticked can the entity user submit. And the handbook flags a trap — no email acknowledgement is sent for a submission in the Entity Master.
Fully diluted basis
Paid-up capital on a fully diluted basis equals paid-up shares on a fully diluted basis multiplied by face value, in INR. "Fully diluted" means the total number of shares that would be outstanding if all possible sources of conversion are exercised:
- Equity shares — as equity shares;
- CCDs and CCPS — as equivalent equity shares. Where the conversion ratio is not fixed upfront, the company may enter the maximum number of equity shares possible on conversion, in compliance with the pricing guidelines;
- Share warrants — equivalent equity shares considering 100% exercise upfront; and
- ESOPs — equivalent equity shares, considering 100% exercise upfront.
The handbook carries a note that is easy to miss and easy to get wrong on the FIRMS portal: "If a start-up company has issued convertible notes, the same shall not be included in the paid-up capital on fully dilution basis."
Every other convertible instrument — CCDs, CCPS, warrants, ESOPs — is grossed up as if fully exercised. Convertible notes are not, even though a start-up may have issued a great many of them.
The reason is that they are separately reported: Form CN is the return for the issue or transfer of convertible notes to a person resident outside India. Including them in the Entity Master's fully diluted figure would double-count. Note also the accompanying instruction that only capital instruments held by persons resident outside India on a repatriable basis are to be reported.
Business user registration on the FIRMS portal
The second step is completed after entity user registration. From the login box, Registration form for New Business User asks for the BU's name, a unique user name, email, mobile and correspondence address, and then four fields that decide the filing:
- Whether the Business User is for Form InVi. If yes, the CIN or LLPIN of the investee company is not required, because InVi reports foreign inflows in an investment vehicle and not foreign investment in an entity. If no, the CIN or LLPIN is required.
- IFSC code of the bank branch to which reporting will be made — to be selected carefully, since not all branches are incorporated in the FIRMS application, only those specified by the bank. If the branch is not listed, the applicant should contact its AD bank.
- Authority letter attachment in the specified format, common for all forms filed in SMF, together with the PAN card of the individual registering.
- Company CIN or LLPIN of the Indian investee company, from which PAN and entity name auto-populate.
After submission, the registration is verified by the AD bank branch concerned, and approval or rejection is communicated by email.
The two registrations on the FIRMS portal are approved by different people. The entity user's authority letter goes to the RBI. The business user's goes to the AD bank branch identified by the IFSC code entered on the form.
That makes the IFSC field consequential rather than administrative. Choose the wrong branch and the registration sits with a branch that has no relationship with the entity and no reason to approve it. Choose a branch that is not incorporated in the FIRMS application and it cannot be selected at all.
The practical sequence is to confirm with the AD bank which of its branches is enabled on FIRMS before starting the business user registration, and to route the entity's inward remittances through that branch.
Practical checklist for the FIRMS portal
- Register on the FIRMS portal as soon as foreign inward remittance is expected.
- Complete entity user registration first; business user depends on it.
- Use the individual's PAN, not the company's, in the entity user form.
- Prepare the authority letter in the specified format for both registrations.
- Confirm the FIRMS-enabled branch and its IFSC with the AD bank first.
- Compute paid-up capital on a fully diluted basis, exercising warrants and ESOPs in full.
- Exclude convertible notes from that figure and report them on Form CN.
- Remember there is no acknowledgement email for an Entity Master submission — check the record.
Common mistakes on the FIRMS portal
- Entering the company's PAN in the entity user registration.
- Reporting Indian shareholding in the foreign investment tab.
- Grossing up convertible notes into fully diluted capital.
- Selecting a branch not enabled on FIRMS.
- Reporting investor-wise in the Foreign Investment Info tab instead of issue-wise.
- Assuming an acknowledgement confirms the Entity Master went through.