Step 1: Create Login on RBI FIRMS Portal

The company must create a Business User (BU) account on the FIRMS portal.

Steps:

Visit FIRMS Portal
Select “Registration for New Business User”
Submit CIN, PAN, company details, and email ID
Approval received from RBI via email

Once approved, the company can file FC-TRS.

Step 2: Determine Applicable Pricing Guidelines

RBI requires that share transfer valuation follows:

Discounted Cash Flow (DCF) method for unlisted companies
SEBI pricing formula for listed companies

A CA or merchant banker valuation certificate is required.

Step 3: Collect All Required Documents

You must gather the following:

From the Company

Board resolution approving transfer
Shareholding pattern
Declaration on compliance with FDI policy

From Transferor/Transferee

KYC documents
FEMA declarations
Share transfer agreement
SH-4 (if applicable)

Step 4: Execute Share Transfer Deed

Depending on share transfer type:

Form SH-4 for resident-to-non-resident transfers
Gift deed for gift transfers
Share Purchase Agreement (SPA) for sale transactions

Step 5: File FC-TRS on RBI FIRMS Portal

Steps in the Business User dashboard:

Login as Business User
Select Single Master Form (SMF)
Choose FC-TRS
Enter mandatory details:
- Transferor & transferee details
- Share class, quantity, price
- Fair value (as per valuation)
- Mode of transfer (sale/gift)
Upload all documents
Submit the form to the Authorized Dealer (AD) Bank

Step 6: AD Bank Review & Approval

The AD bank reviews:

Valuation
FEMA compliance
KYC
Remittance details
Uploaded documents

If corrections are required, the AD bank will raise a query, which must be resolved promptly.

Once satisfied, the AD bank approves and forwards the report to RBI.

Step 7: RBI Final Approval

After AD bank approval, the form is automatically shared with RBI.
Once verified, the transaction is considered completed and compliant.

The acknowledgment is available on the FIRMS portal for future records.

Timeline for FC-TRS Submission

✔ FC-TRS must be filed within 60 days of share transfer or receipt of funds (whichever is earlier).
Late filing attracts FEMA penalties, compounding fees, and possible AD bank rejection.

Documents Required for FC-TRS

Mandatory

Valuation certificate
Share Transfer Agreement / SH-4
FIRC (Foreign Inward Remittance Certificate)
KYC of foreign investor
Board Resolution
Declaration by transferor/transferee

Additional (if applicable)

Gift deed
Consent letters
Previous FC-GPR/FC-TRS filings
CSR or UBO declarations

Common Mistakes That Lead to Rejection

❌ Incorrect valuation method
❌ Mismatch between share price and valuation
❌ Missing KYC from AD bank
❌ Mismatched share numbers
❌ Incorrect CIN/PAN details
❌ Failure to upload clear documents
❌ Delayed filing beyond 60 days

Benefits of Accurate FC-TRS Filing

✔ Fully compliant FDI reporting
✔ Smooth investment transactions
✔ Boosts investor confidence
✔ Avoids FEMA penalties
✔ Ensures legality of ownership transfer

Conclusion

FC-TRS filing is a crucial part of FDI compliance in India.
By following the step-by-step process outlined above—preparing valuation, executing documents, filing on FIRMS portal, and coordinating with the AD bank—you can ensure a seamless and fully compliant share transfer.

SavingMantra can assist you with:
✔ FIRMS portal registration
✔ End-to-end FC-TRS filing
✔ Valuation certificate coordination
✔ Documentation and AD bank queries

The information provided in this blog is for general informational and educational purposes only and should not be construed as legal, tax, or professional advice. While every effort has been made to ensure accuracy and compliance with the applicable provisions of the Companies Act, 2013 and related rules, laws and regulations may change over time and interpretations may vary based on specific facts and circumstances.

All services are subject to applicable laws, rules, and government approvals prevailing at the time of execution.

Step-by-Step Process for FC-TRS Filing