FLA Return Filing in India: Who, When & How

You raised a foreign round two years ago, moved on, and forgot the paperwork ever existed. Then a quiet annual filing you have never heard of falls due on 15 July, and RBI expects it from you even though no money moved this year at all. That filing is the FLA return.

The FLA return (Foreign Liabilities and Assets return) is the annual filing every company with foreign investment on its books owes the Reserve Bank of India by 15 July. It is based on your outstanding position as on 31 March, not on any transaction during the year, which is exactly why so many funded startups do not know it exists. This guide covers what the FLA return is, who must file it, the due date, the FLAIR portal, and how to handle audited versus unaudited numbers.

1 What is the FLA return?

The FLA return, or Foreign Liabilities and Assets return, is an annual return that Indian entities file with the Reserve Bank of India under FEMA. It captures two things as on the close of the financial year: your foreign liabilities (the FDI and other foreign investment you have received) and your foreign assets (any investment you have made abroad).

RBI uses the aggregated data to compile India’s external balance sheet and its International Investment Position. In other words, your FLA return is a statistical return, not a tax return. It does not ask you to pay anything, but it is a mandatory FEMA filing, and skipping it is a contravention like any other.

The single most important thing to understand is what triggers it. The FLA return is driven by an outstanding position, not by a transaction. If a non-resident holds shares in your company on 31 March, or you hold shares in a foreign entity on 31 March, you owe an FLA return for that year, whether or not anything new happened during the year.

2 Who has to file the FLA return?

The primary keyword here is “outstanding”. Any Indian entity that has foreign investment on either side of its balance sheet as on 31 March must file the FLA return. In practice that means:

• An Indian company that has received FDI (equity shares, CCPS or CCDs issued to a non-resident) that is still outstanding on 31 March.
• An Indian company or LLP that has made overseas investment (ODI) into a foreign entity that is still outstanding on 31 March.
• LLPs, partnership firms and other entities that have received foreign investment or invested abroad, not just companies.
• A company that received foreign investment in an earlier year and did nothing new this year, but the investment is still on its books.

The reverse is also worth stating plainly: if you have never received foreign investment and have never invested abroad, you do not file the FLA return. And if a non-resident subscribed to your shares but the money was fully bought back or the shares fully transferred back to residents before 31 March, so that nothing is outstanding, you would generally not have an FLA obligation for that year.

3 The 15 July due date

The FLA return is due by 15 July each year, reporting the position as on 31 March of that year. Because 31 March is the standard financial year end for most Indian companies, the return covers the year that just closed.

For FY 2025-26 (the position as on 31 March 2026), RBI extended the due date to 31 July 2026. Extensions like this are announced by RBI from year to year and should not be assumed in advance, so plan around 15 July and treat any extension as a bonus.

4 The FLAIR portal

The FLA return is filed online on the RBI FLAIR portal (Foreign Liabilities and Assets Information Reporting system). You cannot email a form or file it through your AD bank; it goes directly to RBI through FLAIR.

Before you can submit anything, the entity has to be registered on FLAIR and a user has to be created. This registration step is the part that trips people up on 14 July, because it is not instant and the portal is not always cooperative.

5 Audited or unaudited numbers?

Here is the practical tension. The FLA return is due 15 July, but very few companies have finished their statutory audit by then. RBI anticipates this, so the rule is straightforward:

• If your accounts are audited by 15 July, file the FLA return with the audited figures.
• If your accounts are not audited by 15 July, file with unaudited (provisional) figures so you still meet the deadline.
• Once the audit is done, if the audited numbers differ from what you filed, submit a revised FLA return with the audited figures, typically by end September.

The point to take away is that a pending audit is never a reason to miss 15 July. File provisionally, then revise. Missing the deadline while waiting for the audit is the worst of both worlds: you still had to file, and now you also owe a late fee.

6 A worked example

The clearest way to see how the FLA return behaves is to follow one company across two years.

7 If you miss it: the Late Submission Fee

Missing the FLA return is a FEMA contravention, but it is a fixable one. For periodic returns like the FLA return, RBI allows you to regularise a late filing by paying a Late Submission Fee (LSF), which is a flat ₹7,500 for these returns. That is far cheaper than the day-based penalties on some other filings, but it is still a real cost for something that could have been avoided with a calendar reminder.

For larger, older or more serious breaches, RBI may require compounding instead of LSF, which is applied for through the RBI PRAVAAH portal (application fee around ₹11,000, plus the compounding amount RBI sets). Whichever route applies, keep every payment challan and acknowledgement; lawyers and acquirers in diligence always ask for them.

8 Your FLA return checklist

1. Confirm whether you have foreign investment (FDI received or overseas investment made) outstanding as on 31 March.
2. Register the entity on the RBI FLAIR portal well before July and confirm your login works.
3. Pull together the 31 March figures: paid-up capital, non-resident shareholding, reserves and surplus, and the value of foreign investment on both sides.
4. File the FLA return on FLAIR by 15 July, using audited figures if available, otherwise unaudited (provisional) figures.
5. Save the FLAIR acknowledgement as proof of filing.
6. Once the audit is done, file a revised FLA return with audited figures if they differ, typically by end September.
7. Set a recurring 15 July reminder so the return is filed every year the foreign investment is outstanding, even in years with no new transaction.
8. If you have already missed a year, regularise it via the flat ₹7,500 LSF (or compounding for larger breaches) and keep the challan.

9 FAQs

Disclaimer: This article is general information as of August 2026 and is not legal or professional advice. FEMA rules, RBI portals, due dates and fees can change. Confirm your specific obligations with a qualified professional before filing.