Reporting Forms 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.
Nine reporting forms sit on the FIRMS portal, each tied to a specific event — FC-GPR on issue to a non-resident, FC-TRS on transfer between a resident and a non-resident, LLP-I and LLP-II for LLPs, and CN, ESOP, DI, DRR and InVi for the rest.
The nine reporting forms and their triggers
| Form | Trigger |
|---|---|
| FC-GPR | At the time of issue of an equity instrument to a person resident outside India |
| FC-TRS | At the time of transfer of an equity instrument between a resident and a non-resident person |
| LLP-I | Report filed by an LLP which has received FDI as a capital contribution |
| LLP-II | Report for transfer of capital contribution or profit sharing of an LLP from a resident to a non-resident or vice versa |
| CN | Issue or transfer of convertible notes to a person resident outside India |
| ESOP | Issue of ESOP by an Indian company to an employee resident outside India |
| DI | Reporting of downstream investment or indirect foreign investment |
| DRR | Issue or transfer of a depositary receipt |
| InVi | Units of an investment vehicle issued to a person resident outside India |
All nine are filed in the Single Master Form on the FIRMS portal by a registered business user. The handbook singles out two: "Mainly there are two Forms used in regular transactions, which are Form FC-GPR and Form FC-TRS."
The two reporting forms that matter most
The distinction between the first two reporting forms is the one to get right, because everything else follows from it.
FC-GPR is for an issue — the Indian company creates and allots new equity instruments to a person resident outside India, and money comes into the company. It is the company's filing.
FC-TRS is for a transfer — existing equity instruments change hands between a resident and a non-resident, in either direction, and the money passes between the shareholders rather than into the company.
Two consequences. A secondary sale by a founder to a foreign investor is FC-TRS, not FC-GPR, however much it feels like fundraising. And a transfer between two non-residents, or between two residents, falls outside FC-TRS altogether, because the form is keyed to a transfer between a resident and a non-resident.
The Entity Master's Foreign Investment Info tab reflects the same split, asking for a description of each event — rights, bonus, share swap, merger, demerger, ESOP, NR to R transfer, R to NR transfer.
The two LLP reporting forms
LLP-I and LLP-II mirror FC-GPR and FC-TRS for a limited liability partnership. LLP-I reports FDI received as a capital contribution; LLP-II reports the transfer of capital contribution or profit sharing from a resident to a non-resident or vice versa.
The distinction matters for the Entity Master too. For a company, the portal asks for paid-up capital on a fully diluted basis and the number of instruments issued. For an LLP it asks instead for total capital contribution in INR and the percentage of capital contribution received from the foreign entity, and the foreign portfolio investment field is disabled — because an LLP cannot receive portfolio investment.
Form DI — the one that reaches beyond the investee
Form DI reports downstream investment or indirect foreign investment: where an Indian company that has itself received foreign investment invests in another Indian company, that second investment is indirect foreign investment in the second company.
Form DI is only half the obligation. The handbook records the other half in its Entity Master instructions:
"The Indian companies who have made downstream investment in another Indian company for which it is considered as indirect foreign investment … shall inform the same to the Indian investee company for the purpose of providing details of indirect foreign investment in Entity Master."
So the investing company files the Form DI, and separately tells the investee company, which then reports the indirect foreign investment in its own Entity Master. Without that communication the investee cannot complete its master record accurately, and its sectoral cap computation will be wrong — because the cap is a composite limit that includes indirect foreign investment.
In a group with several Indian layers this is a chain of notifications, not a single filing. It is worth mapping who must tell whom before the first downstream investment is made.
The four remaining reporting forms — CN, ESOP, DRR and InVi
- Form CN reports the issue or transfer of convertible notes to a person resident outside India. Convertible notes are the instrument the Entity Master expressly excludes from paid-up capital on a fully diluted basis, so Form CN is where they are captured. The Entity Master's instrument-type field lists convertible notes separately, "in case of start-ups".
- Form ESOP reports the issue of ESOP by an Indian company to an employee resident outside India. Note the direction — this is an Indian company granting options to an employee abroad. Options granted the other way, by an overseas entity to a resident employee, sit on the outbound side of the regime.
- Form DRR covers the issue or transfer of a depositary receipt, matching the Indian Depositary Receipt entry in the list of permitted non-debt inbound investments.
- Form InVi covers units of an investment vehicle issued to a person resident outside India. It is the only form for which the business user registration does not require the CIN or LLPIN of an investee company, because it reports foreign inflows in an investment vehicle and not foreign investment in an entity.
The annual return that sits alongside the reporting forms
Separately from these event-driven reporting forms, the handbook reproduces the Annual Return on Foreign Liabilities and Assets — the FLA return filed with the RBI's Department of Statistics and Information Management as at end-March each year, opening with identification particulars: name of the Indian company, PAN, CIN and contact details.
The FLA appears again on the outbound side, where the undertakings a bank takes before an overseas remittance include a confirmation that "the Annual Return on Foreign Liabilities and Assets have been submitted to RBI up to the current financial year" — and where a delay in filing it attracts a Late Submission Fee.
Practical checklist for the reporting forms
- Classify the event first — issue or transfer — then pick from the reporting forms.
- Use FC-TRS for a founder's secondary sale to a foreign investor.
- Check the transfer is actually between a resident and a non-resident.
- For an LLP, use LLP-I and LLP-II, and report percentage of capital contribution.
- File Form CN for convertible notes and keep them out of fully diluted capital.
- On a downstream investment, file Form DI and notify the investee company.
- Map the notification chain in a multi-layer Indian group.
- Keep the FLA return current — it gates outbound remittances.
Common mistakes
- Filing FC-GPR for a secondary transfer.
- Missing Form DI on a downstream investment.
- Filing Form DI but never telling the investee company.
- Reporting convertible notes in the Entity Master's diluted capital.
- Using a company form for an LLP capital contribution.
- Letting the FLA return lapse and blocking a later outbound remittance.