What corporate legal services does Corporate Legit provide?

Corporate Legit offers India Entry Services, International Taxation, Direct & Indirect Taxation, Secretarial & Corporate Legal Compliances, Foreign Direct Investment, Intellectual Property Rights, Licensing and Registration, company registration services, Merger and Amalgamation (M&A), Litigation, Virtual CFO Services, International Advisory, Audit Services, and Registration of NGOs.

What India Entry Services do you offer?

India Entry Services helps foreign companies establish operations in India. The service assists with business structuring, necessary approvals, and compliance requirements for foreign businesses seeking to enter the Indian market.

What does your Corporate Secretarial practice cover?

Our Corporate Secretarial practice handles statutory compliance requirements for companies operating in India, including corporate legal documentation, board meeting management, and regulatory filings.

What are your Corporate Restructuring services?

Corporate Legit’s restructuring services include mergers and acquisitions, demergers, and corporate restructuring activities in accordance with regulatory requirements.

What Intellectual Property services do you provide?

We provide trademark search and registration services in IP databases, along with other intellectual property protection services, to safeguard clients’ IP rights in India.

How does Corporate Legit handle taxation matters?

Our taxation practice provides advice under Direct & Indirect Taxation, including income tax planning, GST compliance, double taxation avoidance advisory, and international taxation matters, to ensure clients remain compliant with Indian tax laws

What Registration & Licensing Services do you offer?

Corporate Legit provides registration and licensing services to help businesses obtain the necessary operational permits and registrations to conduct business legally in India.

What are your Regulatory Compliance & Audit Services?

We provide Corporate Compliance services to help businesses meet their statutory obligations and remain compliant with Indian regulatory requirements, along with supporting them through audit services in India whenever needed.

Do you provide Virtual CFO Services?

Yes, Corporate Legit offers Virtual CFO services for businesses requiring financial management expertise without a full-time Chief Financial Officer.

What makes Corporate Legit’s team qualified?

The senior members of the Firm possess professional qualifications in law, accountancy, company secretarial practices and management with international class experience from working with world-class advisory firms, including Big-4 accounting firms and international law firms.

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Yes, Corporate Legit provides Registration of NGOs (Non-Government Organisation) services to help establish non-profit entities in India.

How can businesses contact Corporate Legit?

Businesses can contact Corporate Legit at +91 9990607535, email at office@thecorporatelegit.com, or visit the office at A-77, Second Floor, Sector-4, Noida 201301, New Delhi NCR, India.

What is a FEMA compliance audit in India?

A FEMA compliance audit India is a structured review of a company's foreign exchange transactions and regulatory filings under FEMA 1999 and RBI's rules and master directions. It identifies missed FC-GPR and FC-TRS filings, FLA return gaps, ODI Annual Performance Report non-filings, valuation non-compliance, and instrument misclassifications that constitute compoundable contraventions.

2. How often should a foreign-owned Indian company conduct a FEMA compliance audit?

At minimum, a FEMA audit for foreign companies India should be conducted annually and mandatorily before any significant transaction including a new equity round, a secondary share sale, an M&A transaction, or an IPO. Violations discovered proactively can be compounded on the company's timeline. Violations discovered during due diligence must be compounded on the transaction's timeline.

What is the penalty for missing the FC-GPR filing deadline?

FC-GPR must be filed within 30 days of share allotment. Late filings attract a Late Submission Fee calculated on the amount involved and the delay period. If the delay is prolonged, the violation becomes compoundable under Section 13 of FEMA, attracting a penalty of up to three times the amount involved or ₹ 2,00,000 for non-reporting contraventions under the April 2025 revised compounding framework.

Can FEMA violations be regularised without going through the compounding process?

Some violations can be regularised by paying a Late Submission Fee through the FIRMS portal, which covers delayed FC-GPR and FC-TRS filings within a defined window. Violations beyond the LSF window, structural violations, or violations involving incorrect instrument classification or wrong FDI route require formal compounding through RBI.

What happens if a company's APR for ODI is not filed for multiple years?

The AD bank is required to block further outward remittances from the Indian entity until all outstanding APRs are filed. Additionally, the non-filing is a FEMA contravention subject to compounding. Backlogged APRs must be filed along with audited financial statements of the overseas entity for each year missed.

Does a FEMA compliance audit cover transfer pricing?

A FEMA compliance audit India focuses on foreign exchange compliance under FEMA and RBI regulations. Transfer pricing compliance under the Income Tax Act is a separate exercise. However, intercompany transactions reviewed during a FEMA audit often have transfer pricing implications and the two reviews are best conducted together for companies with significant related-party cross-border flows.

FIRC and KYC: Key Documents for FDI Reporting India

June 10, 2026
Gaurav Vashistha
FDI
0

Table of Content

FIRC and KYC — Key Documents Required for FDI Reporting in India

What Is FDI Reporting in India and Why Does It Matter?

FDI reporting in India is the statutory process of reporting foreign investment received by an Indian entity to the Reserve Bank of India under FEMA 1999, through the RBI FIRMS portal. It is carried out primarily through FC-GPR filing when shares or convertible securities are issued to a non-resident investor. Two documents sit at the heart of this process — the FIRC and the 6-Pointer KYC — and without both, the filing cannot be completed.

FDI reporting in India refers to the statutory process of reporting foreign investment received by an Indian entity to the Reserve Bank of India under the provisions of the Foreign Exchange Management Act 1999 through the RBI FIRMS portal. Such reporting is generally carried out through FC-GPR filing in cases where shares or convertible securities are issued by an Indian company to a person resident outside India.

The RBI has provided the list of documents that are required to be submitted along with the FC-GPR Form. Out of those, the following two documents are considered the most important:

FIRC — Foreign Inward Remittance Certificate b. 6 Pointer KYC — Know Your Customer

FDI reporting in India through Form FC-GPR broadly involves:

Verification of the foreign investor’s identity through KYC; and
Confirmation of receipt of foreign investment through FIRC

which together form the basis for FC-GPR filing within prescribed timelines under FEMA and RBI regulations.

What Are the Three Pillars of FDI Reporting Compliance in India?

FDI reporting in India rests on three pillars — confirming the investment is genuine and identifiable through KYC verification, confirming it has actually been received in India through the FIRC, and ensuring it is properly recorded through FIRMS portal filings. Non-compliance with any of these three pillars can trigger penalties, late submission fees, and compounding proceedings under FEMA.

FDI reporting in India ensures that all foreign investments are:

Genuine and identifiable (through KYC verification)
Actually received in India (through FIRC)
Properly recorded and regulated (through FIRMS portal filings)

Non-compliance with FDI reporting in India requirements may lead to penalties, late submission fees, and compounding proceedings under FEMA.

What Are the Key Documents Required for FDI Reporting in India?

The two most critical documents for FDI reporting in India are the 6-Pointer KYC — which verifies the identity of the foreign investor through the overseas remitter bank — and the FIRC (Foreign Inward Remittance Certificate) — which confirms that foreign funds have actually been received in India by the Indian company. Both are issued by the Authorised Dealer Bank and must be attached to the FC-GPR filing without exception.

A. What Is the 6-Pointer KYC and What Does It Contain?

The KYC is a due diligence process required under the Foreign Exchange Management Act, 1999 and regulated by the Reserve Bank of India to verify the identity and credibility of a foreign investor before accepting FDI reporting in India.

The KYC report generally contains the following 6 important details:

Name of the Remitter: Full legal name of the foreign individual/entity making the investment
Registration Number of the Remitter: Registration or incorporation number of the foreign entity / Passport number of individual
Address of the Remitter: Registered office / permanent address of the investor
Name of Remitter’s Bank: Name of the overseas bank remitting the funds and responsible for providing the KYC confirmation
Bank Account No. of Remitter’s Bank: Account number maintained by the foreign investor with the overseas bank
Duration of Banking Relationship with Remitter: Duration of banking relationship between the investor and the overseas bank

Who Issues and Verifies the KYC?

The 6-Pointer KYC document is generally issued by the Indian AD Bank based on the KYC confirmation and information received from the overseas remitter bank through SWIFT communication or official banking channels.

The process flow is generally as follows:

Indian AD Bank → Sends SWIFT request for KYC information → Foreign Remitter Bank → Sends KYC information through SWIFT response → Indian AD Bank issues 6-Pointer KYC

B. What Is the FIRC and What Does It Contain?

The FIRC (Foreign Inward Remittance Certificate) is a document issued by the Authorised Dealer (AD) Bank in India as proof that foreign investment has been received from outside India. The FIRC plays a crucial role in FDI reporting in India and serves as documentary evidence of receipt of foreign inward remittance by the Indian company.

The FIRC generally contains the following essential details:

Name & Address of Remitter (Foreign Investor)
Name of Beneficiary (Indian Company)
Amount Received (Foreign currency & INR equivalent)
Date of Receipt of Funds
Purpose Code (e.g., investment in equity shares)
Bank Reference Number / FIRC Number
Mode of Transfer (SWIFT/Bank transfer)
Certification by the AD Bank

C. How Does FC-GPR Filing Work With These Documents?

At the time of FC-GPR filing with the RBI, the above documents are attached as mandatory supporting documents and serve as important evidence regarding the receipt of foreign investment in India.

However, in many cases, the AD Bank raises queries and seeks resubmission due to the following common mistakes:

Mismatch in details mentioned in FIRC and KYC
Absence of a stamp or signature of a banking official
Expiry of FIRC validity (generally considered valid for one year by banks)
Failure to attach both FIRC and KYC to Form FC-GPR
Mismatch between details mentioned in Form FC-GPR and supporting documents

What Is the Timeframe to Issue KYC and FIRC for FDI Reporting in India?

There is no fixed statutory deadline for banks to issue FIRC and KYC — some AD Banks issue both documents within a few working days, while others may take several weeks or even a month. Since FC-GPR filing must be completed within 30 days of share allotment under FEMA, proper coordination between the Indian AD Bank, the overseas remitter bank, and the foreign investor is critical to avoid delays and penalties.

These documents are issued and provided by the AD Bank. The timeline for issuance of FIRC and KYC depends upon the circumstances of the transaction and the banking partner involved. Certain banks issue both documents within a few working days, whereas some banks may take several weeks or even a month to issue the same.

Proper coordination between the Indian AD Bank, overseas remitter bank, and foreign investor is therefore extremely important to obtain the documents on time and complete FDI reporting in India within the prescribed timelines.

Conclusion

The FIRC and 6-Pointer KYC are two of the most important documents required for FDI reporting in India. These documents not only establish the identity of the foreign investor and proof of receipt of foreign investment but also form the foundation for FC-GPR filing with the RBI through the FIRMS Portal.

The proper preparation, verification, and timely collection of these documents are essential to ensure smooth reporting compliance under FEMA and to avoid delays, re-submissions, penalties or compounding proceedings. Therefore, Indian companies receiving foreign investment should maintain proper coordination with the AD Bank and the foreign investor to ensure accurate and timely FDI reporting in India.

If your company needs support with FDI reporting, FC-GPR filing, or end-to-end FEMA compliance, CorporateLegit provides expert advisory services to ensure your foreign investment is reported accurately and on time — every time.

Frequently Asked Questions

What is the deadline for FC-GPR filing after receiving foreign investment?

FC-GPR filing must be completed within 30 days from the date of receipt of funds or date of allotment of shares — whichever is earlier — on the RBI FIRMS portal. Delayed filing requires prior RBI approval through the Authorised Dealer Bank and may attract a compounding fee under FEMA. This makes timely collection of FIRC and KYC documents critical to meeting the deadline.

What happens if there is a mismatch between the FIRC and the KYC document?

A mismatch between the FIRC and KYC is one of the most common reasons for AD Bank query and re-submission during FDI reporting in India. The names, amounts, account details, and remittance references must match exactly across both documents and the FC-GPR form. Any discrepancy must be resolved with the AD Bank before filing, as incorrect submissions can trigger FEMA non-compliance proceedings.

Can FDI reporting in India be done without a FIRC?

No. The FIRC is a mandatory document for FC-GPR filing and cannot be substituted. It is the primary evidence that foreign funds have actually been received in India. Without a valid and current FIRC, the AD Bank will not process the FC-GPR submission on the FIRMS portal.

How long is a FIRC considered valid for FDI reporting purposes?

Banks generally consider a FIRC valid for one year from the date of issuance. If the FC-GPR filing is not completed within this period, the company may need to obtain a fresh FIRC or a revalidation from the AD Bank before proceeding. This is another reason why early coordination with the bank is strongly recommended.

Who is responsible for ensuring FDI reporting in India is completed on time?

The primary responsibility for FDI reporting in India lies with the Indian company receiving the foreign investment. The company must coordinate with its AD Bank to obtain the FIRC and KYC, ensure the FC-GPR is filed within 30 days of share allotment, and retain all supporting documents for future regulatory scrutiny. Directors of the company can face personal liability for FEMA non-compliance if filings are delayed or incorrect.