What Is Form CN?
A startup recognised by DPIIT can raise money from foreign investors by issuing convertible notes – instruments that convert into equity later. The issue must be reported to the RBI in Form CN within 30 days.
Form CN is filed on the RBI’s FIRMS portal and reviewed by the startup’s AD bank. Transfers of convertible notes between residents and non-residents are also reported in Form CN.
Convertible notes reported to the RBI
- Eligibility checked
- FIRMS filing done
- Conversion planned
Who Files Form CN?
- DPIIT-recognised startups issuing convertible notes
- Startups raising seed funding from abroad
- Parties transferring convertible notes across borders
- Founders planning early-stage foreign funding
Benefits
Fast fundraising
Raise funds before fixing a valuation.
FEMA compliance
Avoid penalties for non-reporting.
Investor confidence
Investors see a clean regulatory trail.
Smooth conversion
Correct records make later conversion easier.
Documents Required
- DPIIT recognition certificate
- Convertible note agreement and terms
- FIRC and KYC of the investor
- Board resolution approving the issue
- Declaration by the startup
Form CN Filing Process
Eligibility
We confirm the startup and investment amount qualify.
Funds received
Money received through banking channels.
Filing
Form CN filed within 30 days.
Bank review
AD bank queries answered.
Conversion
Equity issue later reported in FC-GPR.
Common Mistakes to Avoid
- Not DPIIT recognised – Only recognised startups can issue convertible notes to non-residents.
- Below the minimum amount – Each tranche must meet the minimum amount set by the rules.
- Late reporting – Late filing needs a late submission fee.
- Forgetting conversion reporting – Conversion into shares needs a separate filing.
Related Filings
FC-GPR
When notes convert into equity shares.
FC-TRS
When shares are transferred later.
FLA return
Annual return to the RBI.
ROC filings
Allotment filings when shares are issued.
Why Choose Vaidam Consultancy for Form CN Filing
FEMA experts
We handle RBI FIRMS filings and the supporting documents.
Clear quote upfront
You receive our fee and all charges before we begin.
On-time reporting
Filed within the RBI time limit to avoid late submission fees.
Bank coordination
We work with your AD bank until the form is approved.
Frequently Asked Questions
Startups recognised by DPIIT, subject to the FEMA rules.
Within 30 days of issuing the convertible notes.
Yes, a minimum amount applies per tranche under the rules.
Yes. Transfers between residents and non-residents are also reported in Form CN.
Shares issued on conversion are reported in Form FC-GPR.