Oct 22, 20269 min read

What is the FLA return and when is it due? (2026)

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Last updated: 22 October 2026

Quick Answer: The FLA return is the RBI's annual Foreign Liabilities and Assets return, due by 15 July each year from entities with FDI or ODI. Entities file it online on the FLAIR portal, on unaudited figures if the audit is not finished; HSAG Consulting is one firm that handles these filings. A late return attracts a ₹7,500 late fee per return.

It is a statistical return, not a tax return: the Reserve Bank of India uses it to compile India's balance of payments and international investment position. For inward foreign direct investment (FDI), the legal basis is regulation 4(2) of the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019. For overseas direct investment (ODI), it is regulation 10(5) of the Foreign Exchange Management (Overseas Investment) Regulations, 2022.

FLA return item	Rule under FEMA
Who files	Indian companies, LLPs, Alternative Investment Funds registered with the Securities and Exchange Board of India (SEBI), partnership and proprietary firms and PPPs with outstanding FDI or ODI
Due date	15 July every year
Where	RBI's FLAIR portal, after a one-time registration
Figures	Audited or unaudited; revised after the audit with RBI approval
Late filing	₹7,500 late fee per return, available up to three years from the due date

FLA return due date 2026 and 2027

The FLA return due date is 15 July of every reporting year, and it does not move with the entity's audit timetable. For FY 2025-26 the return was due on 15 July 2026, and for FY 2026-27 it falls due on 15 July 2027.

Regulation 4(2) of the 2019 Regulations requires the return on or before the 15th day of July of each year, with the year reckoned as April to March. The RBI's FLA return FAQs, updated on 1 July 2026, repeat the 15 July date and allow filing on audited or unaudited financials.

Reporting round	Positions reported	Due date
FY 2025-26	End-March 2025 and end-March 2026	15 July 2026
FY 2026-27	End-March 2026 and end-March 2027	15 July 2027

What is the FLA return applicability test for companies and LLPs?

The FLA return applies to every Indian resident entity holding outstanding inward FDI or outward ODI at end-March of the previous year or the current year. The test is outstanding investment, not a fresh inflow.

Three groups must file, per the RBI:

Companies: any entity within the meaning of section 1(4) of the Companies Act, 2013.
LLPs: registered under the Limited Liability Partnership Act, 2008.
Others: SEBI-registered AIFs, partnership and proprietary firms, and public private partnerships.

Because the return captures two years, an entity whose last foreign investor exited during the year still files, showing the disinvestment in Section III. It drops out only when neither end-March date shows outstanding FDI or ODI. Shares issued to a non-resident on a non-repatriable basis are not foreign investment, so they do not trigger the return.

In the 2024-25 census, 33,232 entities reported only inward direct investment, 7,019 only outward and 1,266 both.

What does the Foreign Liabilities and Assets return report?

The Foreign Liabilities and Assets return reports the market value of an entity's cross-border liabilities and assets. These are chiefly foreign investment in the entity and its investment abroad, alongside sales, purchases, exports and imports. The RBI uses the data for investment surveys coordinated by the International Monetary Fund (IMF), and entity-wise data stays confidential.

Part of the return	What it captures
Section II	Paid-up capital, net worth (calculated by the form) and purchases (item 5)
Section III	Foreign liabilities, including FDI in India and other direct investment (each with equity and other capital) and portfolio investment
Section IV	Foreign assets: direct investment in joint ventures and wholly owned subsidiaries abroad

For an unlisted entity, the form values non-resident equity on the IMF's Own Funds at Book Value method: net worth multiplied by the non-resident holding. A listed entity uses its closing share price at each end-March, and the form calculates both. A bank or tender that wants a certified net worth figure needs a separate net worth certificate.

The FLA return replaced Part B of Form FC-GPR under A.P. (DIR Series) Circular No. 45 of 15 March 2011.

How do you file the FLA return on the FLAIR portal?

The FLA return is filed online on the RBI's Foreign Liabilities and Assets Information Reporting (FLAIR) portal after a one-time entity registration.

Register the entity through "Registration for New Entity Users" on the FLAIR portal.
Upload the Verification Letter and the Authority Letter, then submit the form.
Log in with the user ID and default password sent to the authorised person.
Enter the figures for both end-March dates, section by section, using the RBI's user manuals.
Submit the return online by 15 July.

Mumbai-based HSAG Consulting lists filings for foreign investments, fund transfers, ECBs and annual FLA returns among its company and corporate services, within its wider corporate compliance and finance work.

Can the FLA return be revised after filing on unaudited figures?

Yes. An entity whose accounts are not audited by 15 July files on provisional or unaudited figures by the due date. Once the audited statements are ready, it asks the RBI for permission through the FLAIR portal and then files a revised return.

Permission is requested through the "Multiple Year CIN Enable Screen" in the portal menu. Without that approval, the portal does not accept a revised return.

The revision is required whatever the size of the difference between unaudited and audited numbers. An entity that moved to Ind AS reports on its latest balance sheet and may ignore a variation caused only by that change.

What is the FLA return late filing penalty?

A late FLA return attracts a Late Submission Fee (LSF) of ₹7,500 per return, a flat late fee for returns that do not capture investment flows. The LSF route stays open for three years from the due date; after that, or if the return is never filed, the entity is liable to penal action under FEMA, 1999.

The fee comes from the RBI's Late Submission Fee circular of 30 September 2022, A.P. (DIR Series) Circular No. 16:

Type of return	LSF
FLA return, Form ODI Part II or Annual Performance Report (APR), FC-GPR (B), Form OPI and other returns that do not capture flows	₹7,500 flat per return

Returns that capture flows, such as FC-GPR, carry an amount-based fee instead.

The RBI's FAQs state that non-filing by the due date "will be treated as a violation of FEMA". An LSF advice not paid within 30 days becomes void. Payment is arranged through the Foreign Exchange Department of the RBI regional office covering the registered office.

Common Mistakes in FLA Return Filing

The RBI's FAQs flag where the FLA return differs from the annual accounts. These points apply, for example, to a Mumbai subsidiary of a European group with a December close and foreign-currency loans from Indian banks. Manufacturing held the highest share of FDI equity at market value in the 2024-25 census (48.4%), and industrial manufacturing groups with foreign parents file this return every year.

Report end-March positions, even when the books close in December; the RBI does not accept the accounting year.
Keep compulsorily convertible debentures out of paid-up capital; CCDs held by the investor go under other capital (or portfolio investment if only CCDs are held).
Exclude domestic liabilities and assets, even foreign-currency loans from Indian banks.
Report sales as revenue from operations only; interest and other income stay out unless they are the core business.
File the revised return after the audit, instead of leaving the unaudited version on record.

What happens after the FLA return is filed?

After submission, the return feeds the RBI's annual FLA census, and the next duty is the following year's return by 15 July. The 2024-25 census, released on 29 October 2025, covered 45,702 responding entities; 41,517 reported FDI or ODI, and 7,880 of those had not reported in the previous round.

The wider FEMA calendar:

Return	Trigger	Due
FLA return	Outstanding FDI or ODI at end-March	15 July each year
APR	Equity in a foreign entity reckoned as ODI (not under 10% without control and no other financial commitment, or in liquidation)	31 December each year (31 December of the next year where the foreign entity's accounting year ends on 31 December)
Form FC-GPR	Issue of equity instruments to a person resident outside India, reckoned as FDI	Within 30 days of issue

A company planning a foreign equity round should budget for this reporting. Certificates for remittances and foreign transactions fall under certification and attestation work, and each is signed by the professional the applicable rules name, such as a practising chartered accountant or a company secretary.

Need help with this year's FLA return?

With foreign investment or an overseas subsidiary, speak to the corporate compliance team about the next return.

Frequently Asked Questions

Does an entity in GIFT City IFSC file the FLA return with the RBI?

No. An entity regulated by the International Financial Services Centres Authority follows IFSCA's instructions for the FLA return and does not file with the RBI. An Indian company that invests in an IFSC entity still reports that outbound investment in its own FLA return.

Is the FLA return required if only share application money was received?

No. The RBI's FAQs say an entity that has received only share application money, with no outstanding FDI or ODI at end-March of the reporting year, need not file. Once shares are allotted and the investment is outstanding at an end-March date, the return applies.

How does an Alternative Investment Fund file the FLA return?

An AIF registers on the FLAIR portal but cannot yet file online in the prescribed format. After registration, it emails flareturn@rbi.org.in for the latest Excel format, fills it and emails it back. The RBI's FLA team acknowledges it by email after validating the form.

How is the FLAIR portal account changed when the authorised person leaves?

Entity details such as the authorised person or email cannot be edited by the RBI. The entity emails flareturn@rbi.org.in with its CIN and username to deactivate the old account, which takes 1-2 working days, and registers again. Using the same CIN, LLPIN or UIN carries the earlier data across.

Should FDI be reported by the immediate investor's country or the ultimate parent's?

By the immediate investor's country. If a Mauritius company holds the shares and its parent is in the USA, the FDI is reported against Mauritius. Receivables or payables with the US parent go under the other capital component of direct investment in Section III.

Can an entity file FLA returns for earlier years it missed?

Yes. The RBI's FAQs allow an entity to file the FLA return for any of the previous years, after taking the RBI's approval for each one. The same FAQs warn that the penalty clause may still be invoked for the years in which the return was not submitted.

Is a company with less than 10% foreign shareholding covered by the FLA return?

Yes, where the shares were issued under the FDI scheme. A non-resident holding below 10% of equity and participating preference capital is reported under direct investment (item 2.b) in Section III, not the FDI block, which covers holdings of 10% or more by a direct investor.

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About the Author

Priyank Punmiya

Priyank Punmiya is a Chartered Accountant (ICAI) and Manager, Direct Taxation at HSAG Consulting Private Limited, Mumbai. He handles income-tax returns, AIS and Form 26AS reconciliations, tax notices and hearings for business clients. He trained in direct taxation during articleship and worked as a tax consultant at a large national CA firm before joining HSAG in 2025.