In a significant step towards easing foreign investment compliance, the Reserve Bank of India (RBI) has operationalized the bulk upload functionality for three key forms on the FIRMS Portal — FCGPR, FCTRS, and DI, effective 01st July 2025.
This update is set to streamline reporting under FEMA (Foreign Exchange Management Act) and reduce the time-intensive process professionals’ face when handling multiple foreign investment transactions.
What Has Changed?
The bulk upload facility now allows Business Users (BUs) to file multiple submissions in one go using CSV templates, rather than manually submitting each form individually. This is particularly beneficial for companies, startups, law firms, and professionals managing high-volume FDI, share transfer, or downstream investment transactions.
Scope of Forms Covered
- Form FCGPR – Filed when a company issues shares or convertible securities to a person resident outside India against FDI.
- Form FCTRS – Filed for transfer of shares/convertible securities between a resident and non-resident.
- Form DI – Filed for reporting of downstream investment by an Indian entity which has received foreign investment.
Where to Access the Bulk Upload Utility
- The functionality is available to all Business Users on the FIRMS portal.
- Templates for each form in CSV format can be downloaded post login.
- The Business User Manual is available under the same section to provide detailed guidance on how to prepare and validate the CSV files before upload.
Also Read: RBI Digital Lending Directions 2025: A Unified Framework for Transparency and Consumer Protection
Benefits of Bulk Upload Facility
- Saves time: Multiple transactions can now be uploaded in one consolidated file.
- Reduces error rate: Standardized CSV templates and validations help avoid inconsistencies.
- Ensures timely compliance: Critical for avoiding penalties under FEMA for delayed or incorrect filings.
- Supports high-volume filers: Ideal for private equity, venture capital, and multinational companies handling frequent capital inflow/outflow.
Important Points to Note
- Effective Date: The facility is available for filings from 01/07/2025 onwards.
- CSV Format Validation: Templates include mandatory fields, dropdowns, and format checks – incorrect data may lead to rejection.
- Digital Signature: The bulk file submission still requires authentication through the Business User’s Digital Signature Certificate (DSC).
- Acknowledgement: On successful upload, separate acknowledgment references will be generated for each form submitted.
- Individual Review: Each submission, though uploaded in bulk, will still be reviewed separately by the AD Bank/RBI.
Frequently Asked Questions (FAQs)
Q1: Can a regular user access this functionality?
No, the bulk upload feature is accessible only to Business Users (BUs) registered with RBI on the FIRMS portal.
Q2: Is any additional registration or permission required to use this feature?
No additional permission is required. Business Users can access this feature once logged in. Ensure your DSC is active and registered on the portal.
Q3: Can I combine different form types (FCGPR, FCTRS, DI) in one CSV?
No. Each form has a separate CSV template. Separate files must be uploaded for each form type.
Q4: What happens if one entry in the CSV is incorrect?
The portal validates each entry. If there is an error in one row, that particular form may be rejected while others may go through. Errors will be flagged during the validation stage before final submission.
Q5: What kind of transactions are still required to be filed manually?
Any complex cases requiring special RBI approval, missing mandatory fields, or involving legal clarifications may still need to be handled individually or directly through the AD Bank.
Conclusion
The launch of the bulk upload facility marks a significant milestone in India’s foreign investment compliance landscape. For professionals managing corporate legal and financial compliance, this update ensures greater efficiency, accuracy, and accountability. It also aligns with the government’s broader agenda of promoting Ease of Doing Business and Digital India.
Disclaimer: This article provides general information existing at the time of preparation and we take no responsibility to update it with the subsequent changes in the law. The article is intended as a news update and Affluence Advisory neither assumes nor accepts any responsibility for any loss arising to any person acting or refraining from acting as a result of any material contained in this article. It is recommended that professional advice be taken based on specific facts and circumstances. This article does not substitute the need to refer to the original pronouncement.
