A ₹10 crore Series A in foreign investment, and an FC-GPR filing nobody had made: caught and resolved before it could delay or reprice the round.
The situation
A startup closing a Series A round of roughly ₹10 crore in foreign investment discovered during diligence that an earlier round's FCGPR filing with the RBI had never been made, putting the new round's compliance at risk.
The approach
The lapsed FCGPR filing was reconstructed and regularized with the RBI, and the compliance trail was rebuilt to satisfy the new round's diligence requirements before closing.
The outcome
The Series A closed on schedule, with the FEMA compliance gap resolved rather than becoming a condition subsequent that could have delayed or repriced the round.
For the mechanics of the FC-GPR filing itself, and where it typically goes wrong, see our briefing on FC-GPR filing.
What "reconstructed and regularized" actually involved
The original FC-GPR should have been filed within 30 days of the earlier round's allotment; by the time it surfaced in Series A diligence, the entity was well past the window where a standard Late Submission Fee filing alone would clear it. The team rebuilt the full paper trail (the FIRC, the original valuation certificate, the CS certificate confirming the allotment) and filed under the RBI's regularization route, treating the gap as a compliance defect to be cured, not a disclosure to negotiate around in the term sheet.
Why this mattered for the round
An unresolved FEMA filing gap doesn't just risk a penalty: it blocks the entity from filing any subsequent FEMA return, including the FC-GPR the new Series A round itself would need. Clearing the earlier lapse wasn't a nice-to-have; it was a precondition for the new round being able to file its own paperwork at all.
A composite, anonymized account built from the kind of engagement Clairvoyis regularly handles, not a case-by-case record of a single named client.