By Naraway
In this article
Every rupee of foreign investment that enters an Indian company leaves a paper trail with the Reserve Bank of India. When that trail is late, the company ends up on a public list.
RBI has published a summary of every FEMA compounding order it passed since 1 March 2020. Compounding is how a company settles a breach of the foreign exchange law by paying an amount RBI fixes. We read all 4,494 orders on that list, up to 29 September 2026, and sorted them by the rule each one breached.
One form stands out. A late or missing FC-GPR, the report a company files after issuing shares to a foreign investor, appears in 1,539 of them.
The List in Numbers
Source: Naraway analysis of RBI's "Summary information on compounding orders", orders dated 5 March 2020 to 29 September 2026. One order can cite more than one breach.
Which Rules Companies Break
Each order names the regulation breached. Grouped by what the rule actually asks for, the pattern is clear: most breaches are not about where the money came from. They are about telling RBI late.
Three of the top six are deadlines that follow a single investment round. The money arrives and must be reported. The shares must then be issued within a fixed window, and the issue must be reported again. A round that misses all three can produce three breaches in one order.
The Deadlines Behind the List
Under the current rules, FEMA 395/2019, each step has its own clock:
| Filing or step | Deadline | Rule |
|---|---|---|
| Issue shares against money received | Within 60 days of receipt, or refund within 15 days after that | Reg. 3.1(I)(A) |
| Form FC-GPR | Within 30 days of issuing the shares | Reg. 4(1) |
| Form FC-TRS (transfers between residents and non-residents) | Within 60 days of the transfer or payment, whichever is earlier | Reg. 4(3) |
| FLA annual return | By 15 July every year | Reg. 4(2) |
Source: RBI, FEMA 395/2019-RB. Orders before October 2019 cite the older FEMA 20/2000 and FEMA 20(R)/2017 rules, which set similar reporting duties.
On paper, each deadline is simple. In practice they overlap with company law filings, bank paperwork and valuation reports, and each one depends on the step before it. The dates that matter are the ones on the allotment and the bank's confirmation, not the date someone remembers to file.
Who Ends Up on the List
The list is not made up of careless small firms alone. Indian subsidiaries of well-known global groups have settled FC-GPR breaches in the last two years, among them CEVA Logistics India, Genpact India, Fresenius Kabi India, Voestalpine High Performance Metals India and Micro Focus Software India.
The largest FC-GPR settlements on the list:
| Company | Order date | Amount |
|---|---|---|
| Hinduja Renewables Energy Private Limited | 7 Dec 2023 | ₹5.00 crore |
| Pfizer Healthcare India Private Limited | 21 May 2021 | ₹2.11 crore |
| Little Internet Private Limited | 15 Sep 2023 | ₹1.50 crore |
| Myoung Shin India Private Limited | 17 Jul 2023 | ₹1.14 crore |
| Newgen DigitalWorks Private Limited | 20 Jan 2022 | ₹1.08 crore |
Source: RBI compounding order summaries. Orders that cite FC-GPR, often alongside other breaches in the same order.
What a Late Filing Costs
Most settlements are modest. Half of the FC-GPR orders were for ₹92,190 or less, and 88% were under ₹10 lakh. The amount is not the whole cost, though. A compounding application takes months, the order is published with the company's name, and an open breach tends to surface at the worst moment: during due diligence for the next round, an acquisition, or when profits are first sent abroad.
RBI's own list shows how steady this is. Between 41% and 52% of each year's orders involved a missed foreign-investment reporting deadline:
| Year | All orders | Citing FC-GPR | Any reporting delay |
|---|---|---|---|
| 2020 (from March) | 346 | 158 | 179 (52%) |
| 2021 | 568 | 218 | 271 (48%) |
| 2022 | 638 | 204 | 260 (41%) |
| 2023 | 758 | 268 | 369 (49%) |
| 2024 | 727 | 228 | 320 (44%) |
| 2025 | 787 | 265 | 376 (48%) |
| 2026 (to 29 Sep) | 670 | 198 | 272 (41%) |
Source: Naraway analysis of RBI compounding order summaries.
Why the Paperwork Is Worth It
The reporting load exists because the money keeps coming. India recorded US$94.53 billion in gross foreign direct investment in FY 2025-26, its highest ever, and US$58.85 billion in equity inflows. Computer software and hardware drew the most equity of any sector, US$13.9 billion. Singapore was the largest source, at US$19.8 billion.
For a company bringing capital into India, the market is not the hard part. The hard part is the sequence of filings that follows every round, each with its own clock, and a public list for those who miss one.
Before the Next Round
The companies on RBI's list rarely missed a deadline on purpose. Most found out when an investor's lawyer or an auditor asked for the FC-GPR acknowledgement and there was none. Which filings a particular round triggers, in what order, and what the bank and the company secretary need for each, depends on how the round is structured.
Part of Naraway's research series India Market Entry in 2026.
In short
FC-GPR is the form an Indian company files with the Reserve Bank of India within 30 days of issuing shares to a foreign investor (FEMA 395/2019, Regulation 4(1)). Of the 4,494 FEMA compounding orders RBI published between March 2020 and September 2026, 1,539 (34%) cite a late or missing FC-GPR. That makes it the single most common breach on RBI's list, ahead of late reporting of the money received (1,095 orders) and shares issued after the deadline (555).
- RBI published 4,494 FEMA compounding orders from March 2020 to September 2026, totalling ₹336.6 crore.
- 1,539 of them (34%) cite a late or missing FC-GPR. It is the most common breach on the list.
- Nearly half of all orders (2,047) involve a missed foreign-investment reporting deadline of some kind.
- Half of FC-GPR settlements were under ₹92,190. Six crossed ₹1 crore, the largest ₹5 crore.
- Subsidiaries of global groups appear on the list alongside small private companies.
Sources
- Summary information on compounding orders issued on or after March 1, 2020, Reserve Bank of India
- Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019 (FEMA 395/2019-RB), Reserve Bank of India
- Foreign Exchange Management (Transfer or Issue of Security by a Person Resident outside India) Regulations, 2017, Regulation 13.1, Indian Kanoon
- India FDI Report FY 2025-26, India Briefing
Frequently Asked Questions
What is the due date for FC-GPR?
Not later than 30 days from the date the shares are issued to the foreign investor, under Regulation 4(1) of FEMA 395/2019-RB.
How common is late FC-GPR filing?
It is the most common breach in RBI's published compounding orders. 1,539 of the 4,494 orders issued from March 2020 to September 2026 cite it.
What does it cost to settle a late FC-GPR?
In RBI's published orders, half of FC-GPR settlements were ₹92,190 or less and 88% were under ₹10 lakh. Six crossed ₹1 crore, the largest being ₹5 crore.
Is FC-GPR the only filing a foreign-funded company owes RBI?
No. The money received, the timing of the share issue, transfers between residents and non-residents (Form FC-TRS) and the annual FLA return, due by 15 July, each carry their own deadline.
Where can compounding orders be checked?
RBI publishes a summary of every compounding order passed on or after 1 March 2020 on its website, with the company name, the provisions breached, the date and the amount.
