FLA Return (Annual Return on Foreign Liabilities and Assets): due date and filing guide

Who must file the FLA return?

Indian companies and LLPs that have received foreign direct investment, or made overseas direct investment, in the previous year or in earlier years with the investment still outstanding, must file the FLA return. Other entities such as AIFs and investment vehicles covered by RBI's instructions also file.

The return is a statistical return. It captures the stock of foreign liabilities and assets as at 31 March, based on the entity's accounts, and feeds into India's international investment position.

Due date and revision

The FLA return is due by 15 July every year for the financial year ended 31 March. If the accounts are not audited by then, the entity files on unaudited figures and then submits a revised return based on audited accounts by 30 September. Modification or deletion of a submitted return, and filing after the window, generally need RBI's approval through the portal process.

What information is reported?

The form captures details of the entity, its foreign shareholders and their percentage holdings, the market or book value of foreign equity and other capital, transactions with foreign direct investors such as loans and trade credit, and similar details for any overseas subsidiaries or joint ventures. Values must be consistent with the audited financial statements, FC-GPR filings and the APR for overseas investments.

How the FLA return relates to other filings

The FLA return pulls together positions that are reported transaction by transaction elsewhere. Equity received from foreign investors should agree with FC-GPR and FC-TRS filings, loans from foreign group entities with ECB returns, and investments in overseas subsidiaries with Form FC and the APR. Reconciling these before filing reduces RBI queries and helps auditors, who increasingly check FEMA compliance as part of statutory audit reporting.

Registering on FLAIR

First-time users register on the FLAIR portal by submitting an online user registration form, uploading a signed authority letter and a verification letter, and then logging in with a password and OTP. Registration needs details of the entity's CIN or LLPIN and authorised person. Allow time for registration approval before 15 July, as the portal sees heavy traffic in the final weeks.

Late filing and common mistakes

The FLA return is a non-flow return, so under RBI's September 2022 circular the Late Submission Fee is a flat ₹7,500 per return. Continued non-filing is a contravention of FEMA, and pending FLA returns can hold up other approvals or filings with the AD bank.

Typical mistakes include assuming small or loss-making companies are exempt, reporting face value instead of the required valuation basis, missing the September revision after audit, and confusing FLA with FC-GPR.

Practical tips for a smooth filing

Start preparing in June with draft accounts, and keep the FLAIR login active from year to year. Assign one person to own the filing so that the authority letter and email OTP reach the right person. If the entity's foreign investment was fully repatriated during the year, confirm with RBI's FAQs whether a return is still required for that year before deciding not to file.

Step by step

1. 1Check applicability

   Confirm the entity has outstanding FDI or ODI as at 31 March.

2. 2Register on FLAIR

   Create a user with authority and verification letters if not registered.

3. 3Compile data

   Pull foreign equity, loans and overseas investment figures from the accounts.

4. 4Submit by 15 July

   File the return on unaudited or audited figures.

5. 5Revise by 30 September

   If filed on unaudited figures, submit the audited revision.