FDI reporting isn't one filing — it's three, each with its own deadline. Here's the table worth keeping on the wall.
"FDI reporting" is often used as a catch-all, but it's actually three distinct filings with three distinct deadlines — and treating them as one task is where the gaps happen.
The three filings
FC-GPR reports fresh equity allotted to a foreign investor — due within 30 days of allotment. FC-TRS reports a transfer of existing shares between a resident and a non-resident, in either direction — due within 60 days of the transaction. The annual FLA return reports the full foreign liabilities and assets position of the entity as of 31 March, and is due by 15 July every year, regardless of whether any transaction happened that year — an entity with foreign investment on its books files an FLA return every year, not just in years with activity.
A filing table worth keeping on the wall
FC-GPR: 30 days from allotment. FC-TRS: 60 days from transfer. FLA return: 15 July annually. Miss any of the three and the entity can't file its next FEMA return until the missed one is regularised — through the Late Submission Fee mechanism for straightforward delays, or full RBI compounding for more serious lapses.
Where this usually breaks down
Most missed FDI filings aren't the result of not knowing the rule — they're the result of the reporting deadline sitting with finance while the transaction itself was closed by legal or the founders directly, with nobody explicitly owning the RBI filing. The fix is procedural, not technical: one person owns FEMA reporting for the entity, full stop, and every equity transaction — allotment or transfer — triggers that person before the deal closes, not after.
This article is general information, not tax or legal advice for your situation. Speak with a qualified adviser before acting.