Scope of this roadmap
This roadmap is sized for a captive centre of 100–500 seats, owned through a wholly owned private limited company in a sector open to 100% FDI under the automatic route. Timings are shown only where a rule fixes them. Everything else depends on the authority, the case and the applicant.
IMC’s stated timeline for a capability centre is “typically operational in 90 to 120 days, subject to approvals”. Treat any timeline as an estimate until the approvals in your case are known.
The ten steps
| Step | What happens | Fixed time | Authority |
|---|---|---|---|
| 1. Feasibility and location | Business case, operating model, city and state screening. Incentives often pay more outside the main metros | None | Group; state IT or industries department |
| 2. Choose the vehicle | Usually a private limited subsidiary; check the land-border rule | None | Group; FIF/NSWS if the government route applies |
| 3. Incorporate | SPICe+ with AGILE-PRO-S: incorporation, DIN, PAN and TAN, with GST, EPFO and ESIC registration | None | MCA (Central Registration Centre) |
| 4. Bank, capital and FC-GPR | Receive share capital through an AD bank, allot shares at not less than fair value, report the issue | Allot within 60 days of receipt; FC-GPR within 30 days of issue | AD bank; RBI FIRMS portal |
| 5. Office | Managed space or lease; decide on STPI or SEZ registration. Confirm stamp duty relief before signing the lease | None | Landlord; STPI or SEZ authority |
| 6. State incentive registration | Register under the state GCC or IT policy before claiming | Set by each policy | State IT or industries department |
| 7. Hire leaders and staff | Labour Code registrations, appointment letters, payroll, EPF and ESIC | None | State labour department; EPFO; ESIC |
| 8. Inter-company agreement and transfer pricing | Services agreement with the parent; choose the 15.5% safe harbour (five-year option) or seek an APA | None | CBDT / Income Tax Department |
| 9. IT, security and data protection | Systems, security safeguards and a DPDP compliance plan | DPDP core duties from 13 May 2027 | MeitY; Data Protection Board |
| 10. Go-live and claims | Start operations, declare commencement of business, begin incentive claims | Commencement within 180 days of incorporation | MCA; state department |
Incorporation in more detail
The company-law steps follow the general set-up roadmap:
- Apostille or legalise the parent’s constitutional documents, board resolution and the IDs of foreign subscribers and directors.
- Obtain a digital signature certificate for at least one proposed director; DINs are applied for within SPICe+.
- Reserve the name through RUN or SPICe+.
- File SPICe+ with the MoA, AoA and AGILE. One filing covers incorporation, DIN, PAN and TAN, and the linked form can also obtain GST, EPFO and ESIC registrations. Foreign subscribers attach a signed physical MoA and AoA.
- Receive the certificate of incorporation with CIN, PAN and TAN.
The company needs at least two shareholders and two directors, one of whom meets the 182-day residence test.
FEMA steps and deadlines
| Filing | Deadline | Where |
|---|---|---|
| Share allotment | Within 60 days of receiving funds; otherwise refund within the next 15 days | Company and AD bank |
| Pricing | Not below fair value set by a SEBI-registered merchant banker or a CA; valuation under 90 days old | Valuer |
| FC-GPR | Within 30 days of issue | RBI FIRMS portal |
| FLA return | On or before 15 July each year | RBI |
| Land-border prior report | Before the money is remitted | FIF/NSWS portal |
See the FEMA compliance calendar for recurring filings.
Registrations before the first hire
- Shops and establishments and professional tax, under state law.
- EPFO and ESIC, which SPICe+ can trigger. The EPF Scheme, 2026 was notified on 29 June 2026 under the Code on Social Security.
- Labour Code registrations. The four codes apply from 21 November 2025, with a single registration, licence and return replacing multiple filings. State rules also apply.
- GST. Low-risk applicants can opt for automated registration within three working days. Since the Finance Act 2026 removed the special place-of-supply rule for intermediary services, services to the parent follow the general rule and can qualify as exports.
- IEC from DGFT where the centre imports equipment or exports.
- Employment visas for any expatriate leaders, through the Indian mission; these are for highly skilled professionals, not routine roles.
Points where order matters
- Lease before incentive check. Several state GCC policies tie stamp duty relief to IT parks, SEZs and STPIs. Confirm eligibility before signing.
- Incentive registration before claims. Maharashtra issues a Registration Certificate and requires units to stay operational for at least 10 years. Tamil Nadu’s scheme admits up to 50 GCCs in its window to 31 March 2027.
- Transfer pricing before the first invoice. The inter-company agreement fixes how the centre is paid. Decide between the safe harbour and an APA before invoicing begins; see tax and transfer pricing.
- Hiring before ELI windows close. The employment-linked incentive covers jobs created up to 31 July 2027; see people and hiring.
- Data protection before go-live. Consent Managers register from 13 November 2026 and core duties apply from 13 May 2027. Breaches of the security safeguards duty carry penalties of up to ₹250 crore.
After go-live
Ongoing compliance includes the annual FLA return, the transfer-pricing accountant’s report (still required; non-furnishing now attracts a fee rather than a penalty under the Finance Act 2026), annual financial statements and returns, director KYC and beneficial-ownership filings. The sources do not give dates for the last group; confirm them with the authority.
What to check next
- Confirm the land-border position of every shareholder and beneficial owner before step 2.
- Check whether the chosen building qualifies for stamp duty relief under the state policy before signing.
- Diary the 60-day allotment and 30-day FC-GPR deadlines from the date funds arrive.
- Register under the state incentive policy before incurring costs you intend to claim.
- Build a DPDP plan against the 13 November 2026 and 13 May 2027 dates.