Article · 18 min read
CCPS SAFE Notes in India: Structure, Investor Rights, and Compliance
Treelife Free Intermediate India
Once you accept you are using CCPS, this is the operator's manual for what that instrument actually carries: 1x non-participating liquidation preference, weighted-average anti-dilution, reserved matters, and the FEMA constraint that bites hardest. For a foreign investor, CCPS cannot be truly unpriced, it must be issued at or above registered-valuer FMV, with an FC-GPR filing inside 30 days. That is the single biggest way an Indian round differs from a Valley SAFE.
- CCPS is India's SAFE substitute: money in now, preference shares that auto-convert to equity on a priced round or liquidity event
- Foreign investors cannot get a truly 'unpriced' instrument; CCPS must be priced at or above registered-valuer FMV under FEMA, with FC-GPR filed within 30 days
- The light 100X iSAFE template and a VC's CCPS use the same instrument but load very different investor rights (liquidation preference, anti-dilution, board seats)