FLA Return Filing: RBI’s Annual Foreign Liabilities and Assets Return
If your company or LLP has taken foreign investment or invested abroad, FLA return filing with RBI is due every year, normally by 15 July. It reports your position as on 31 March, even when nothing moved. We collect the figures, set up your FLAIR access and file.
What it is
The FLA return is an annual statement to the Reserve Bank of India. It shows the foreign liabilities and foreign assets of an Indian entity as on 31 March: shares held by non-resident investors on one side, and investments your entity holds abroad on the other.
RBI uses it to compile India’s external-sector data, so it is filed on RBI’s FLAIR (Foreign Liabilities and Assets Information Reporting) portal and not on the MCA or income-tax portals. It sits alongside the event-based filings you already know, such as FC-GPR and FC-TRS. Our FEMA compliance page lists all the RBI filings in one place.
Who it applies to
Companies with foreign shareholders
Think of a startup that took a seed round from an overseas angel in 2022. If that shareholding is on the books on 31 March, the company files. One foreign shareholder is enough.
Entities investing abroad
A Faridabad exporter that set up a small subsidiary in Dubai files too. So does any company or LLP with overseas direct investment.
LLPs and AIFs
LLPs and SEBI-registered AIFs with FDI or ODI come under the same requirement. The duty applies even in a year with no new transaction.
Why it matters
A return RBI expects
RBI collects it every year from every entity holding FDI or ODI. Filing it keeps you off the defaulter list.
Keeps your FEMA record clean
A clean record helps when you raise the next round. Unresolved reporting delays can also block further overseas investment until they are regularised.
One filing, once a year
The return is annual and the data is mostly drawn from your books. Once set up, it takes days.
Documents required
Entity records
- Certificate of incorporation or LLP registration, with PAN
- CIN or LLPIN and registered address
- Class 3 digital signature certificate of the authorised signatory
- FLAIR registration details and any earlier FLA acknowledgements
Financials
- Audited balance sheet and profit and loss account for the year, or provisional figures
- Share capital and reserves breakdown
- Details of loans and other liabilities to non-residents
Foreign investment records
- Shareholding of non-resident investors and Form FC-GPR or FC-TRS acknowledgements
- Details of any overseas subsidiaries or joint ventures and their financials
- Unique identification numbers for earlier FDI and ODI filings
FLA return at a glance
A quick summary for FY 2025-26, the year just closed, and the year ahead.
| Item | Detail |
|---|---|
| Reporting date | 31 March of the financial year |
| Standard due date | 15 July |
| FY 2025-26 due date | Extended by RBI to 31 July 2026 |
| Revised return with audited figures | 30 September |
| Next return (FY 2026-27) | 15 July 2027, unless RBI extends again |
| Where filed | RBI’s FLAIR portal |
How it works
Register on FLAIR early
Your entity registers on the FLAIR portal. This can take four to six weeks, so we start before the year-end rush.
Pull the figures from your books
We pull share capital, foreign holding, reserves and overseas investment from your books, and tie each to your FC-GPR, FC-TRS or ODI records.
Fill the return and sign
We fill the five sections: identification, financials, foreign liabilities, foreign assets and variance. An authorised signatory signs with a digital signature certificate.
File, then revise
We submit by the due date, using provisional figures if the audit is pending. Once the audit closes, we file the revised return with the final numbers.
Timelines
15 July
The standard due date for the previous financial year’s return. For FY 2025-26, RBI extended it to 31 July 2026.
30 September
Last date to file the revised return with audited figures. If your first filing used provisional numbers, this is when you correct them.
15 July 2027
Due date for the FY 2026-27 return, as on 31 March 2027, unless RBI announces an extension.
What happens if you miss it
Late submission fee
For an annual return like FLA, RBI’s late submission fee is a flat ₹7,500. It is available for three years from the due date.
FEMA penalty
If the delay goes beyond the window, Section 13(1) of FEMA allows a penalty of up to three times the sum involved, or up to ₹2 lakh where it cannot be quantified, plus ₹5,000 a day for a continuing default.
Compounding
In practice, compounding takes months and costs more than filing on time. It is the route once the late fee window has closed.
Frequently asked questions
What is the FLA return?
The FLA return is the annual Foreign Liabilities and Assets return that Indian entities with FDI or ODI file with RBI on the FLAIR portal. It records your position as on 31 March. That means foreign shareholding, loans from abroad and investments held overseas. It is separate from FC-GPR and FC-TRS, which are event-based. We prepare it every year.
Who must file the FLA return?
Every Indian company, LLP or SEBI-registered AIF that has received foreign direct investment or made overseas direct investment, where the position still shows on the balance sheet. The duty applies even if nothing happened during the year. If you are unsure whether it applies to you, send us your shareholding and we will tell you.
What is the due date for FLA return filing?
15 July each year, for the position as on 31 March. For FY 2025-26, RBI extended it to 31 July 2026. The next return, for FY 2026-27, is due 15 July 2027 unless RBI extends it again. We diarise the date for you.
Can I file with unaudited figures?
Yes. You can file by the due date with provisional figures if the audit is pending, then file the revised return with audited figures by 30 September. That avoids a late filing while the auditors finish. We handle both steps and make sure the two sets of numbers reconcile.
I missed the FY 2025-26 FLA return. What now?
File as soon as you can. The 31 July 2026 deadline and the 30 September revised date have passed, so a late submission fee of ₹7,500 applies, and it is available for three years from the due date. Beyond that, compounding is the only route. Acting now keeps the cost low.
Is FLA filing needed if there was no transaction this year?
Yes. Here is the catch: the return reports the outstanding position on 31 March, not the transactions in the year. If foreign investment or overseas investment is still on your balance sheet, you file. Entities holding it throughout the year with no movement still report. We prepare it from your closing balances.
What do I need to register on FLAIR?
You need the entity’s PAN and incorporation details, a Class 3 digital signature certificate for the authorised signatory, and the details of earlier FDI or ODI filings. Registration can take four to six weeks, so start well before the due date. We handle the application and follow up on it.
What is the penalty for not filing the FLA return?
The first consequence is the flat ₹7,500 late submission fee. If the case goes beyond that route, FEMA Section 13(1) allows a penalty of up to three times the sum involved, or up to ₹2 lakh where the amount cannot be quantified, and ₹5,000 a day if the default continues. Filing late costs far less than waiting.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
A flat ₹7,500 late submission fee applies only if the return is filed after the due date. Digital signature certificate costs are separate.
Ready to begin?
Send us your shareholding and year-end figures. We will confirm whether the FLA return applies, then file it on FLAIR.