FLA Return Filing in India

What is the FLA return?

The Annual Return on Foreign Liabilities and Assets (FLA return) gives the Reserve Bank of India a year-end picture of foreign investment in and by Indian entities. It reports the entity's foreign liabilities, such as equity held by non-residents, and its foreign assets, such as investment in an overseas subsidiary, as at the end of March. The RBI uses the data for India's international investment position statistics.

The return is separate from the event-based filings. FC-GPR and FC-TRS report each share issue or transfer as it happens, on the FIRMS portal. The FLA return is a once-a-year statement of the total position, on the FLAIR portal.

Who must file the FLA return?

The RBI's FAQs require the return from Indian-resident entities that have outstanding inward FDI and/or outward ODI at the end of March of the previous year or the current year. Covered entities include:

• Companies incorporated under the Companies Act, 2013, including foreign-owned subsidiaries and joint ventures
• Limited liability partnerships with foreign capital contribution or overseas investment
• Other entities such as SEBI-registered alternative investment funds, partnership firms and public-private partnerships

Filing is still required when no new money came in during the year, because the return reports the stock of investment at both year-ends. An entity whose foreign investors all exited during the year still files, showing the disinvestment. Entities with no outstanding FDI or ODI at either year-end, and entities that only received share application money, need not file. Shares issued on a non-repatriable basis are not treated as foreign investment for this purpose.

What is the FLA return due date?

The due date is 15 July every year, for the position at the end of the preceding March. Most foreign-owned companies in India have not finished their statutory audit by then, so the RBI allows the return to be filed on unaudited or provisional figures by 15 July. Once the audited figures are ready, the entity requests RBI approval through FLAIR and files a revised return, whatever the size of the difference.

How do you file the FLA return on FLAIR?

1. 1

   Confirm the filing obligation

   Check whether the entity had outstanding FDI or ODI at the end of March of the reporting year or the previous year.

2. 2

   Register on FLAIR

   Register the entity on flair.rbi.org.in as a new entity user, uploading the verification and authority letters; credentials are emailed to the authorised person.

3. 3

   Compile the figures

   Prepare equity, debt and other foreign liabilities and assets as at end-March, using audited figures or unaudited figures if the audit is not complete.

4. 4

   File by 15 July

   Complete and submit the online return on FLAIR on or before 15 July.

5. 5

   Revise after audit

   If you filed on unaudited figures, request RBI approval through FLAIR and file the revised return once the audit is complete.

No balance sheet or profit and loss account is attached; only the online return is submitted. The figures should still reconcile with the financial statements, the FC-GPR filings and the shareholding register, because the RBI and later investors or acquirers compare them.

What happens if the FLA return is late or missed?

The RBI's FAQs state that not filing by the due date is treated as a violation of FEMA and that penalty provisions may be invoked. Late submission fees are dealt with through the RBI Foreign Exchange Department regional office where the entity's registered office is located. Filing for earlier years that were missed needs RBI approval through FLAIR, and penalties may apply for those years.

A missed FLA usually surfaces at a bad moment: during a fresh fund-raise, a share transfer, a buyback, an audit query or an acquirer's due diligence. If a year was missed, regularise it before the next transaction rather than during it. We review the filing history, prepare the past returns, seek the RBI approvals and, where needed, handle the late submission fee or compounding.

Common FLA mistakes we see

• Assuming no filing is needed because no new investment came in during the year
• Filing on unaudited figures and never filing the revised return after audit
• Reporting the overseas parent's investment at a value that does not match the books or FC-GPR filings
• Forgetting outward investment (ODI) in an overseas subsidiary when the Indian company also has FDI
• Losing access to the FLAIR login when the person who registered leaves the company

The FLA return sits in the annual cycle alongside the ROC filings, income tax return and transfer pricing report. See our annual compliance calendar for a foreign subsidiary, post-incorporation compliance and transfer pricing for Indian subsidiaries.

Sources: RBI FLAIR portal; RBI FAQs on the FLA return; Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019, regulation 4. Last reviewed: November 2026 · Reviewed by CA Regi Tom Antony, Regi Tom Antony & Associates. General guidance, not advice on your entity's filing position.