AS | Ankit Sarawagi|Founder, CFOmatrix·September 2026·10 min read | FEMA & FDI |
A foreign investor has agreed to put money into your company. The term sheet is signed, the funds are on their way, and you have 30 days from issuing the shares to report it to the RBI. Every one of those reports goes through one place: the FIRMS portal. And you cannot file a single one until two registrations, both approved by your bank, are already done.
The FIRMS portal is the Reserve Bank of India’s online system for reporting foreign investment into and out of India. It houses the Single Master Form (SMF), the common wrapper for FC-GPR, FC-TRS and the other foreign investment returns. This how-to walks through what FIRMS and the SMF are, the two one-time registrations you do first, the 6-pointer KYC you attach, the portal’s common pain points, and why founders who wait until the deadline to start almost always regret it.
- What FIRMS is
- RBI’s Foreign Investment Reporting and Management System, the online portal for all FDI reporting.
- What the SMF is
- The Single Master Form that houses FC-GPR, FC-TRS, LLP-I/II, DI, ESOP, CN and more.
- Two steps first
- Entity Master registration, then Business User registration, both approved by your AD bank.
- KYC needed
- The 6-pointer KYC on the foreign investor, obtained from your AD bank.
- Approved by
- Your Authorised Dealer (AD) bank reviews and approves every registration and SMF.
1 What is the FIRMS portal?
FIRMS stands for the Foreign Investment Reporting and Management System. It is an online portal run by the RBI where Indian companies report foreign investment: money coming in when a non-resident subscribes to your shares, or shares moving between a resident and a non-resident. Before FIRMS, these reports went through email and separate systems. Now they all sit in one place, accessed at the FIRMS portal (firms.rbi.org.in).
Think of FIRMS as the front door and the AD bank as the gatekeeper. You prepare and submit your filing on the portal, but nothing is complete until your Authorised Dealer (AD) bank, the bank that handles your foreign exchange transactions, reviews it and approves it. The RBI sits behind the bank. This is why your relationship with your AD bank matters so much on every FEMA filing.
2 What is the Single Master Form (SMF)?
The Single Master Form (SMF) is the single interface on FIRMS that houses every foreign investment return type. Instead of a different form on a different system for each transaction, you log in to FIRMS, pick the return you need, and file it as an SMF. The AD bank then approves that SMF.
The SMF covers a family of returns. The two you will meet first as a startup are:
| Return | When you file it |
|---|---|
| FC-GPR | When your company issues equity shares, CCPS or CCDs to a non-resident. Due within 30 days of the issue. See our FC-GPR filing guide. |
| FC-TRS | When shares are transferred between a resident and a non-resident. Due within 60 days of the transfer or the funds, whichever is earlier. See our FC-TRS filing guide. |
| LLP-I / LLP-II | For capital contribution into, and transfer of interest in, an LLP with foreign investment. |
| DI, CN, ESOP, DRR, InVi | Downstream investment (Form DI), convertible notes, ESOPs to non-residents, depository receipts and investment vehicles. |
Whichever return applies, the route is the same: it is filed as a Single Master Form on FIRMS and approved by the AD bank. The FLA return is the exception, it is annual and filed on a separate RBI portal (FLAIR), not on FIRMS. For the full map of which return applies to which transaction, see our FEMA and FDI compliance pillar.
3 The two registrations you do first
You cannot walk up to FIRMS and file an FC-GPR. Two one-time registrations come first, in order, and each is approved by your AD bank before you can move on.
Step 1: Entity Master registration
The Entity Master is a record of your company and its existing foreign investment. You register the entity on FIRMS with basic details: CIN, PAN, registered office, and the foreign investment position as it stands. This is the master record every future SMF hangs off. It is a one-time registration per company, though you keep the foreign investment figures updated as you file.
Step 2: Business User (BU) registration
Once the entity exists, a specific person registers as a Business User (BU) and is linked to that entity. The BU is a real individual, a director, company secretary or an authorised signatory, who will actually log in and file returns. The BU registration is submitted with an authority letter and is again approved by the AD bank. Only after the BU is approved can that person prepare and submit a Single Master Form.
4 The FIRMS 6-pointer KYC
When you file FC-GPR, you attach a KYC report on the foreign investor, commonly called the 6-pointer KYC because it certifies six particulars. It confirms who sent the money and from where. You obtain it from your AD bank against the FIRC or inward remittance advice for the funds received. The six points are:
| # | Particular of the foreign investor |
|---|---|
| 1 | Name of the investor |
| 2 | Address |
| 3 | Date of incorporation |
| 4 | Registration number / unique identification number |
| 5 | Name of the investor’s bankers |
| 6 | Nature of business |
Alongside the KYC, an FC-GPR filing typically needs a valuation report (fair value per FEMA pricing guidelines), the FIRC / inward remittance advice, the board and shareholder resolutions, and the share issue details. Get these ready in parallel with the registrations, not after. See our guide on FDI pricing guidelines and valuation for the valuation floor and cap.
5 The FIRMS filing flow
Put the pieces together and the path from a first foreign investment to a filed SMF is a fixed sequence. The two registrations are one-time; from the second filing onward you start directly at the Single Master Form.
Brewly Pvt Ltd is raising a seed round from a Singapore fund. Ankit, a director, registers Brewly’s Entity Master on FIRMS in early August and, once the AD bank approves it, registers himself as the Business User. By the time the fund wires the money and Brewly issues CCPS on 10 September 2026, the registrations are already live. The valuation report and the 6-pointer KYC from the bank are ready, so Brewly files the FC-GPR as a Single Master Form well inside the 30-day window, and the AD bank approves it on the first pass.
A year later, Brewly’s Singapore fund sells part of its holding to an Indian angel. That is a transfer from a non-resident to a resident, so it is an FC-TRS, not an FC-GPR. Because the Entity Master and Business User already exist, Brewly does not repeat the registrations. It logs in, selects FC-TRS as the Single Master Form, and files within 60 days of the transfer. The one-time setup done at the seed round pays off on every filing that follows.
6 Common portal pain points, and why to start early
FIRMS is functional, but it is not always smooth. The recurring problems founders hit are predictable, which is exactly why you plan around them:
- Technical glitches. The portal has downtime, session timeouts and upload issues, often at month end when everyone files at once.
- Slow responses from RBI. If a query goes to the RBI, replies can take time. You cannot assume a quick clarification.
- AD bank turnaround. Registrations and SMFs sit in the bank’s queue. A busy or unfamiliar bank team adds days you did not budget.
- Document mismatches. A KYC that does not match the FIRC, or a valuation date outside the window, gets the SMF sent back for correction, and the clock is still running.
If a deadline does slip despite your best efforts, the fix is a Late Submission Fee (LSF) or, for larger or older breaches, compounding through the RBI PRAVAAH portal. Keep every payment challan. See our guide on the FEMA Late Submission Fee and compounding for how that works.
7 Your FIRMS filing checklist
- As soon as a foreign investment looks likely, register the Entity Master on FIRMS and get it approved by the AD bank.
- Register the Business User (a director or authorised signatory) with an authority letter and get it approved.
- Confirm your AD bank contact for FIRMS and flag the upcoming filing to them.
- Obtain the valuation report at fair value under FEMA pricing guidelines.
- Collect the 6-pointer KYC on the foreign investor from the AD bank against the FIRC / inward remittance advice.
- Keep the board and shareholder resolutions and share issue or transfer details ready.
- Log in as the Business User, file the correct Single Master Form (FC-GPR within 30 days, FC-TRS within 60 days).
- Track the AD bank approval, respond to any query fast, and save the acknowledgement and challans for diligence.
Not sure which FEMA filings you owe?
Use our free FEMA / FDI Filing Checker: answer a few questions about your foreign investors and transactions, and see which returns apply, FC-GPR, FC-TRS, FLA, APR and more, with their due dates.
Check my FEMA filings8 FAQs
What is the FIRMS portal?
What is the Single Master Form (SMF)?
What are the two registrations needed before filing on FIRMS?
What is the FIRMS 6-pointer KYC?
How long does FIRMS registration and approval take?
Related guides & tools
FEMA & FDI compliance for startups (pillar guide) →
FC-GPR: reporting a share issue to a non-resident →
FC-TRS: reporting a share transfer →
FEMA / FDI Filing Checker (free tool) →
AS | Founder, CFOmatrix | Finance Strategy & Compliance CFOmatrix helps Indian startups build finance, tax and compliance functions that stand up to investor due diligence, from process and controls to the filings and the numbers behind them. |
Disclaimer: This article is general information as of September 2026 and is not legal or professional advice. FEMA rules, RBI portals, forms and timelines can change. Confirm your specific obligations with your AD bank and a qualified professional before filing.