What changed
RBI observed that FVCIs investing under the FDI scheme (Schedule 1) were also reporting the same transaction under Schedule 6, causing double reporting. The circular clarifies that such investments must be reported only in FC-GPR or FC-TRS forms, not under Schedule 6. Revised forms FC-GPR and FC-TRS now include a specific remark for FVCIs to declare their investment is under the FDI scheme.
What it means for you
For AD banks, this reduces processing errors and reconciliation burden by eliminating duplicate filings. FVCIs must now upfront decide whether their investment is under the FDI or FVCI scheme and report accordingly, ensuring accurate data. Banks should update their internal systems and customer advisories to reflect the single-reporting requirement.
What you must do
- Update internal reporting procedures to ensure FVCI investments under FDI scheme are reported only via FC-GPR or FC-TRS, not under Schedule 6.
- Advise FVCI clients to use the revised forms with the mandatory remark declaring investment under FDI scheme.
- Train staff to verify that FVCIs do not submit duplicate reports for the same transaction.
- Monitor custodian bank reports for Schedule 6 investments to ensure no overlap with FC-GPR/FC-TRS filings.
Who it affects
AD Category-I banks, SEBI-registered FVCIs, Indian companies receiving FVCI investments, Custodian banks handling FVCI investments
What happens if an FVCI mistakenly reports under both Schedule 1 and Schedule 6?
RBI has clarified that double reporting is not allowed. FVCIs must choose upfront: if under FDI scheme, report only via FC-GPR/FC-TRS; if under Schedule 6, no FC-GPR/FC-TRS is needed. Banks should reject duplicate filings.
Are the revised FC-GPR and FC-TRS forms mandatory from the date of this circular?
Yes, the circular annexes revised forms with a specific remark for FVCIs. AD banks must use these forms for all relevant transactions going forward.