Annual Return on Foreign Liabilities and Assets (FLA)

Annual Return on Foreign Liabilities and Assets (FLA) — July 2026 Deadline

Businesses receiving foreign investment or making investments outside India have additional reporting obligations under FEMA.

One important annual compliance is the Annual Return on Foreign Liabilities and Assets, commonly known as the FLA Return.

The FLA Return is an RBI reporting requirement for eligible Indian-resident entities having outstanding foreign direct investment (FDI) and/or overseas direct investment (ODI) as at the relevant March-end reporting period.

For 2026, the regular due date was 15 July 2026. The RBI’s updated FAQ dated 1 July 2026 confirms that the FLA Return is required to be filed by 15 July of the reporting year.

Many businesses often ask:

“Who needs to file the FLA Return?”

“Is FLA filing mandatory if the accounts are not audited?”

“What happens if the FLA Return is not filed by 15 July?”

“Can the FLA Return be filed using unaudited financial statements?”

Let’s understand the FLA Return and its July 2026 compliance requirements. 🚀

What is an FLA Return?

FLA stands for Foreign Liabilities and Assets.

The FLA Return is an annual return submitted to the Reserve Bank of India under FEMA, 1999.

It captures information relating to an Indian resident entity’s:

Foreign liabilities

Foreign assets

Foreign Direct Investment (FDI)

Overseas Direct Investment (ODI)

Other relevant foreign financial positions

The information collected through FLA reporting is used by RBI for compiling India’s Balance of Payments and International Investment Position statistics and for international statistical surveys.

FLA Return Due Date — July 2026

The standard due date for filing the FLA Return is:

15 July every year

For the 2026 reporting cycle, the due date was:

15 July 2026

The RBI FAQ specifically states that eligible entities are mandatorily required to submit the FLA Return by 15 July based on audited or unaudited financial statements.

Therefore, businesses should not wait for the audit to be completed if audited financial statements are not available by the deadline.

Who Needs to File FLA Return?

The FLA Return may apply to Indian-resident entities that have outstanding FDI and/or ODI as at the end of March of the reporting year and/or the previous year.

Eligible entities can include:

Companies

Limited Liability Partnerships (LLPs)

SEBI-registered Alternative Investment Funds (AIFs)

Partnership Firms

Proprietorship Firms

Public Private Partnerships (PPPs)

Other eligible Indian-resident entities covered by the applicable FEMA framework may also fall within the requirement.

When Does FLA Filing Become Applicable?

FLA filing generally becomes relevant where an Indian entity:

Has received foreign direct investment in India

Has made overseas direct investment

Has outstanding foreign assets or liabilities covered by the FLA reporting framework

The RBI FAQ explains that the reporting requirement applies to entities that have received FDI and/or made FDI abroad and hold foreign assets and/or liabilities in their balance sheets.

FDI in India

FDI means Foreign Direct Investment into an Indian entity.

For example:

An Indian private limited company receives investment from a foreign shareholder.

The foreign investment may need to be considered for FLA reporting based on the applicable FEMA framework and outstanding position at the relevant March-end.

The FLA Return captures information about the foreign investment and related foreign liabilities.

ODI — Investment Outside India

ODI means Overseas Direct Investment.

For example:

An Indian company establishes or invests in a foreign subsidiary or joint venture.

The Indian company may have to report its overseas investment through the FLA Return where applicable.

RBI’s FAQ explains that investments in overseas entities under the ODI framework are reported in the relevant section of the FLA Return.

What Information is Reported in FLA?

The FLA Return generally captures information relating to:

Entity details

Paid-up capital

Reserves and surplus

Financial performance

Foreign investment in India

Investment abroad

Foreign assets

Foreign liabilities

Direct investment relationships

Other relevant financial information

The return is designed to capture foreign liabilities and assets at the relevant March-end reference periods.

Which Financial Year Data is Reported?

The FLA Return works with a March-end reference period.

The information is generally reported for:

Previous March-end

and

Latest March-end

The RBI FAQ specifically states that if an entity’s accounting period differs from March, the FLA reporting should still use the required March reference period rather than simply using the entity’s own accounting closing period.

Can FLA Be Filed Before Audit is Completed?

Yes.

This is one of the most important points for businesses.

If the financial statements have not been audited by 15 July, the entity can file the FLA Return using:

Provisional financial statements

Unaudited financial statements

Once audited financial statements become available, the entity should seek the required permission through the FLAIR portal and submit the revised/updated FLA Return.

Revision of FLA Return After Audit

Suppose a company files FLA based on unaudited accounts.

Later, the statutory audit is completed and some figures change.

The company should:

1️⃣ Obtain the audited financial statements

2️⃣ Raise the required revision request through FLAIR

3️⃣ Obtain RBI approval where required

4️⃣ Submit the revised FLA Return

The RBI FAQ states that revision should be made after taking the required approval, irrespective of the amount or percentage of variation in the audited figures.

How to File FLA Return?

The FLA Return is filed online through RBI’s FLAIR portal.

The basic process is:

Step 1️⃣ Register on the FLAIR Portal

The entity needs to register as a new entity user where required.

Step 2️⃣ Submit Registration Details

The entity provides the required details and uploads documents such as:

Verification Letter
Authority Letter

Step 3️⃣ Receive Login Credentials

After successful registration, the user ID and default password are sent to the authorised person’s email.

Step 4️⃣ Login to FLAIR

Use the credentials to access the FLAIR system.

Step 5️⃣ Select the Applicable Reporting Year

Choose the relevant reporting period.

Step 6️⃣ Enter Financial Information

Provide the required:

Balance sheet information

Profit & loss information

Foreign investment details

FDI information

ODI information

Step 7️⃣ Validate the Return

Review the information carefully.

Step 8️⃣ Submit the FLA Return

Complete the online filing within the applicable deadline.

RBI confirms that FLA filing is made through the Foreign Liabilities and Assets Information Reporting (FLAIR) system.

Documents & Information Required for FLA Filing

Before beginning the filing process, businesses should keep the relevant information ready.

This may include:

Company/LLP details
CIN/LLPIN or relevant identification details
PAN
Audited financial statements, if available
Unaudited/provisional financial statements, where applicable
Balance sheet information
Profit & loss information
Shareholding details
Foreign investor details
Country of foreign investor
FDI details
Overseas investment details
Foreign subsidiary/JV information
Foreign assets and liabilities
Authorised person’s details

The exact information required depends on the entity and its foreign investment structure.

FLA Return — Important Sections

The FLA Return broadly covers information relating to:

Section I — Identification Details

This includes basic information about the reporting entity.

Section II — Financial Details

This can include:

Paid-up capital
Reserves and surplus
Total assets
Total liabilities
Sales
Purchases
Profit-related information

Section III — Foreign Liabilities

This section captures relevant foreign investment and liabilities in India.

Section IV — Foreign Assets

This section captures relevant overseas investment and foreign assets.

The actual fields and reporting requirements should be completed according to the applicable FLA format and RBI instructions.

Who May Not Need to File FLA?

An Indian company, LLP or other eligible entity may not need to file the FLA Return if it does not have any outstanding FDI and/or ODI at the relevant March-end periods covered by the reporting requirement.

For example, if an entity has never received foreign investment and has never made overseas investment, and there is no outstanding FDI/ODI position for the relevant reporting periods, FLA filing may not be required.

However, the applicability should be checked carefully rather than assuming that filing is unnecessary.

What About Share Application Money?

Simply receiving share application money does not automatically mean that an FLA Return must be filed.

The RBI FAQ clarifies that where an entity has received only share application money and does not have outstanding FDI or ODI at the relevant March-end, the FLA Return is not required on that basis alone.

What Happens If FLA is Not Filed by 15 July?

FLA filing is a FEMA-related reporting requirement.

Failure to file the return by the prescribed deadline may be treated as a FEMA violation and the applicable penalty provisions may be invoked.

RBI’s current FAQ specifically states that non-filing before the due date may result in the penalty clause being invoked.

Therefore, businesses should avoid treating the FLA Return as an optional compliance.

Late Submission Fee & Delayed Filing

Where the FLA Return is filed late, the entity may need to follow the applicable RBI process for delayed filing and late submission fee.

For FLA-related late submission matters, RBI advises entities to contact the Foreign Exchange Department of the relevant RBI Regional Office and refer to the applicable FIRMS/FLAIR guidance.

Delayed filing should therefore be addressed as soon as possible rather than leaving the compliance pending.

Can Previous Years’ FLA Returns Be Filed?

Yes.

Where an entity has missed FLA filing for earlier applicable years, it can seek the required RBI approval and file the previous year’s return.

However, delayed filing may attract the applicable consequences under FEMA.

Therefore, businesses should review their previous FLA compliance history before filing the current year’s return.

FLA Return vs FC-GPR vs FC-TRS

These forms serve different purposes.

| ————— | ————————————————- | ——————————————– | —————————————- |

Important:

FLA filing does not replace other FEMA reporting requirements.

A company receiving foreign investment may have multiple FEMA compliances depending on the transactions undertaken.

FLA Return Compliance — Step-by-Step

Step 1️⃣ Check Foreign Investment

Determine whether the entity has:

FDI in India
ODI abroad
Foreign assets
Foreign liabilities

Step 2️⃣ Check March-End Position

Review the foreign investment position as at the relevant March-end dates.

Step 3️⃣ Review Previous FLA Filings

Check whether FLA Returns for previous applicable years were filed.

Step 4️⃣ Collect Financial Data

Keep the relevant:

Balance sheet

Profit & loss statement

Capital details

Foreign investment details

Overseas investment details

Step 5️⃣ Check Audit Status

If audited accounts are available, use the applicable audited figures.

If audit is not complete by 15 July, provisional/unaudited figures can be used as permitted by RBI.

Step 6️⃣ File Through FLAIR

Complete the online FLA Return through RBI’s FLAIR system.

Step 7️⃣ Review Before Submission

Check:

Foreign investor details
Country details
Shareholding
Foreign assets
Foreign liabilities
Financial figures
ODI details

Step 8️⃣ Revise After Audit, If Required

Where provisional/unaudited figures were used, follow RBI’s process for revision after audited accounts are available.

Common Mistakes Businesses Make

Assuming FLA is only applicable to large companies
Missing the 15 July deadline
Waiting for the statutory audit to be completed
Filing incorrect foreign investor details
Reporting incorrect March-end figures
Ignoring overseas investments
Assuming FLA replaces FC-GPR or FC-TRS
Not reviewing previous-year FLA filings
Ignoring FEMA consequences for delayed filing
Forgetting to revise provisional figures after audit
Treating FLA filing as a one-time compliance

The FLA Return is an annual reporting requirement where applicable and should be included in the company’s annual compliance calendar.

FLA Return Compliance Checklist

Eligibility

[ ] Check whether the entity has received FDI
[ ] Check whether the entity has made ODI
[ ] Check outstanding foreign assets/liabilities
[ ] Review relevant March-end position

Financial Information

[ ] Balance sheet details
[ ] Profit & loss details
[ ] Paid-up capital
[ ] Reserves and surplus
[ ] Total assets
[ ] Total liabilities

Foreign Investment Information

[ ] Foreign investor details
[ ] Country of investor
[ ] Shareholding percentage
[ ] FDI details
[ ] ODI details
[ ] Foreign subsidiary/JV details

Filing

[ ] FLAIR registration
[ ] Authorised person details
[ ] Verification/authority documents
[ ] Complete FLA Return
[ ] Review figures
[ ] Submit by 15 July

After Filing

[ ] Keep filing records
[ ] Monitor audit completion
[ ] Revise provisional return where required
[ ] Review previous-year compliance
[ ] Maintain FEMA compliance records

Who Should Pay Special Attention to FLA Compliance?

FLA compliance is particularly important for:

Companies with foreign shareholders

Indian subsidiaries of foreign companies

Companies having overseas subsidiaries

Indian companies with foreign joint ventures

LLPs receiving foreign investment

Eligible AIFs

Partnership firms with applicable foreign investment

Businesses undertaking overseas investment

For these businesses, FLA should be included in the annual FEMA compliance calendar.

Why Accurate FLA Reporting Matters

The information reported through FLA is used by RBI for important external-sector statistics.

RBI uses FLA information for purposes including:

India’s Balance of Payments

International Investment Position

Direct Investment Position by Counterpart Economy

International statistical reporting

Therefore, the figures reported should be consistent with the entity’s books, financial statements and underlying foreign investment records.

Why Businesses Choose TAXAJ

At TAXAJ, we help businesses manage their tax, accounting, FEMA and corporate compliance requirements.

Our services include:

FLA Return Filing

FEMA Compliance

FDI Compliance

ODI Compliance

FC-GPR & FC-TRS Advisory

Company Incorporation

Accounting & Bookkeeping

GST & Income Tax Compliance

ROC & Secretarial Compliance

FEMA & FDI Advisory

Financial Reporting

Startup & MSME Advisory

Whether your company has received foreign investment, established an overseas subsidiary or is planning international expansion, timely FEMA compliance can help reduce regulatory risks.

Final Thoughts

The Annual Return on Foreign Liabilities and Assets is an important FEMA compliance for eligible Indian-resident entities having the relevant outstanding FDI and/or ODI position.

For the 2026 reporting cycle:

FLA Due Date → 15 July 2026

Authority → Reserve Bank of India

Filing Platform → FLAIR

Reporting Period → Relevant March-end financial information

Financial Statements → Audited or unaudited/provisional figures can be used by the due date, subject to RBI’s requirements
Revision → Required process after audited figures become available where provisional data was filed
Non-Filing → May attract FEMA consequences and applicable penalty provisions

The key takeaway is:

“Do not wait for the audit to complete if the FLA deadline is approaching.”

If audited financial statements are not available by 15 July, eligible entities can use available provisional or unaudited figures and subsequently follow the RBI process for revision once audited figures are available.

FLA compliance should be treated as an annual FEMA requirement, not as a one-time filing.

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File on time. Report accurately. Stay FEMA compliant. 🌍📊🏦