FLA Return: Filing Process, Due Date & Compliance Guide

More than $81 billion came into India as foreign investment in FY2024–25. Companies involved in these investments need to file an FLA return with the Reserve Bank of India every year before 15 July.

The FLA return is used by Indian companies with foreign investment to report their external financial position to the RBI. Since it comes under FEMA, non-compliance can create serious issues.

This guide covers everything you need to know about FLA return: what it is, who needs to file it, the due date for 2026, and more.

• Any Indian entity with outstanding FDI or ODI on its balance sheet as of 31 March must file the FLA return.
• The due date for FY 2025-26 is 15 July 2026. If your audit is not complete, you can file using provisional figures and revise it by 30 September. Do not wait for audited accounts.
• Missing the deadline is a FEMA violation, not just an administrative slip. The compounding process that follows can take 6 to 12 months and cost significantly more than the filing itself.

The Foreign Liabilities and Assets (FLA) return is an annual return filed by Indian entities with the RBI. It records the foreign investments outstanding on the balance sheet as of 31 March every year. This includes both inward FDI and ODI made outside India.

It falls under FEMA 1999, governed by A.P. (DIR Series) Circular No. 45 dated March 15, 2011.

However, the FLA return is more than just a compliance requirement. The data collected through FLA returns feeds into:

• India's Balance of Payments
• The International Investment Position
• IMF surveys like the Coordinated Direct Investment Survey

When you file accurately, your numbers contribute to how India's cross-border financial position is reported at a global level.

The FLA return must be filed by any Indian entity that has received FDI or made overseas direct investment in any previous year, including the current one. They should also carry foreign assets or liabilities on their balance sheet as of 31 March.

This covers:

• Companies registered under the Companies Act, 2013.
• Limited Liability Partnerships (LLPs).
• SEBI-registered AIFs, partnership firms, proprietary firms, and PPPs.

You do not need to file the FLA return if:

• You have never received FDI or made an ODI in any previous year, including the current one.
• You have no outstanding foreign assets or liabilities on your balance sheet as of 31 March.
• You issued shares to non-residents only on a non-repatriable basis.
• You received share application money, but shares have not yet been allotted and no actual FDI has been received.

The FLA return must be filed by 15 July every year. For FY 2025–26, you need to report your foreign assets and liabilities as of 31 March 2026 by 15 July 2026.

If your audit is not done by then, you can still file using provisional figures. This keeps you compliant. Once the audit is complete, you can submit a revised return by 30 September 2026. No separate RBI approval is needed for this.

FLAIR stands for Foreign Liabilities and Assets Information Reporting. It is the RBI's official online portal for FLA return submissions.

However, before you can file, you need to register on the portal. This involves:

• Filling in your entity details
• Uploading the required documents
• Submitting the registration form

Once the RBI verifies your details, your login credentials are sent to your registered email address. You don't need a DSC (Digital Signature Certificate) for this.

Note: As of April 2026, the RBI changed the contact email for FLA-related communication. The new email address is flareturn@rbi.org.in, replacing surveyfla@rbi.org.in.

Before logging into the portal, keep all the required documents ready to avoid delays or errors. Here’s what you’ll need:

• PAN and CIN/LLPIN of the entity
• Audited financial statements, provisional if the audit is not yet complete
• Verification Letter in the RBI's prescribed format
• Authority Letter authorizing the person filing the return
• Shareholding pattern showing non-resident equity percentage
• FDI details, including investor names, country of residence, percentage holding, and amount
• ODI details, including details of overseas subsidiaries or joint ventures and equity and loan positions
• Previous year's FLA return
• Employee count and registered address

The FLA return is divided into five sections. Here is what each one covers:

Section I: Identification

This includes basic entity details like the name, PAN, CIN or LLPIN, contact information, NIC-2008 industry code and nature of business. For the NIC code, use the one that matches your primary revenue-generating activity, not just your registered activity.

Section II: Financial Details

The required details include paid-up capital, profit and loss, reserves and surplus, and sales turnover for the reporting year. You need to provide these details for both domestic and foreign sales.

Section III: Foreign Liabilities

This section covers inward FDI, non-resident equity holdings, reinvested earnings attributable to foreign investors, and trade credits received from overseas entities.

Section IV: Foreign Assets

Here, you need to mention ODI in foreign subsidiaries or joint ventures where your equity holding is 10% or more. It also includes overseas loans extended and portfolio investments abroad.

Section V: Variation Report

This section is auto-filled by the portal. It compares this year’s figures with last year’s numbers and highlights any differences. You cannot edit it.

Here is how the filing process works, step by step:

Step 1: Log in to the FLAIR Portal

Use the credentials issued by the RBI. Enter the OTP sent to your registered email or mobile number. On the dashboard, go to the FLA Online Form section, select the relevant financial year, and click 'Start Filing FLA Form'.

Step 2: Fill in Company and Financial Details

Review the auto-filled details like PAN, CIN or LLPIN, and registered address. Then enter your financial figures: paid-up capital, reserves and surplus, and sales turnover. Select the NIC-2008 code that matches your primary activity and indicate whether you are filing on audited or provisional accounts.

Step 3: Report Foreign Assets and Liabilities

Enter FDI details for foreign shareholding in India and ODI details for overseas subsidiaries or joint ventures. Disclose any inter-company loans or receivables. Cross-check everything against your balance sheet as of 31 March before moving ahead.

Step 4: Validate and Submit

Click “Validate” to check for missing details or mismatches. Fix any errors flagged by the system. Once clear, click 'Submit Return'. Download and save the acknowledgement immediately. The RBI does not send a separate confirmation email after submission.

You can revise a previously submitted FLA return, but you need RBI approval before doing so. You cannot simply log in and make changes. To request approval, follow these steps:

• Log in to the FLAIR portal
• Go to "Menu" in the upper left corner
• Select "Multiple Year CIN Enable Screen"
• Choose the relevant year and submit
• Once approved, you can modify or delete the information for that filing period.

If you have received FDI or made overseas investments, the FLA return is not the only FEMA filing you need to know about. There are four core forms: FC-GPR, FC-TRS, APR, and FLA.

• FC-GPR captures inbound investment at the point of share issuance.
• FC-TRS captures secondary transfers of shares between residents and non-residents.
• FLA captures the annual snapshot of all outstanding foreign liabilities and assets.
• APR captures the performance of any overseas investments the Indian entity holds.

Here's how the four differ:

Wondering which form applies when? Here’s an easy way to remember it:

• Was new equity issued to a non-resident? File FC-GPR.
• Was equity transferred? File FC-TRS.
• Does your balance sheet carry any foreign capital or overseas investment as of 31 March? File FLA.
• Do you hold an overseas subsidiary or joint venture as of 31 December? File APR.

Missing the FLA return deadline can result in hefty penalties:

Note that the LSF option is only available within three years of the due date. If you miss that window, you could be looking at formal penal action under FEMA rather than a straightforward fee payment.

Also, the compounding process itself typically takes 6 to 12 months and involves significant management time and legal costs. For a company with Rs. 1 crore in FDI, a FEMA contravention could theoretically attract a penalty of up to Rs. 3 crore.

Several errors come up repeatedly in FLA filings. Most of them are avoidable.

1. Assuming no transactions means no filing

The obligation is based on outstanding FDI or ODI as of 31 March, not on activity during the year. If foreign investment still appears on your balance sheet, you must file.

2. Waiting for audited accounts

File the return with provisional figures by 15 July and revise it by 30 September once the audit is complete. Waiting for audited accounts is one of the most common reasons companies miss the deadline.

3. Treating share application money as equity

Pending allotments should not be reported as equity in the FLA return. This is a common misreporting error that can invite scrutiny.

4. Using an incorrect or inactive email ID

OTPs and system alerts go to the registered email. A wrong or inaccessible address can block your access when it matters most.

5. Confusing FLA with APR

If your company has made ODI, both filings are required. The FLA return is due 15 July. The APR is due 31 December. They are separate filings monitored by different RBI departments.

Here are a few best practices to make the process smoother:

• Maintain ongoing records of foreign equity, loans, and overseas investments throughout the year instead of compiling the data in July.
• Reconcile your foreign asset and liability figures against your 31 March balance sheet before filing.
• If the filing feels complex, get a FEMA compliance expert involved early.
• Watch RBI circulars as rules and deadlines can change.

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The FLA return is a small but important part of how India tracks its foreign investment position. Filing on time, with accurate numbers, keeps you on the right side of FEMA.

Plus, with FDI inflows increasing and FEMA enforcement becoming more systematic, the cost of non-compliance is only going up. The companies that handle this well treat it as a year-round discipline, not a July activity.

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