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Table of Contents
- What is FLA return?
- Foreign Liabilities and Assets Return Applicability — Who needs to file?
- Due Dates & Deadlines For FLA Return 2026
- How to File the FLA Return — Step-by-Step Process
- Special Cases Of FLA Return You Should Know
- Documents You Will Need Before Filing FLA (Foreign Liabilities and Assets) Return
- Penalties for Non-Filing or Late Filing of FLA Return 2026
- How can Mercurius help in filing your FLA return?
- Don't Risk a FEMA Penalty — Let Mercurius Handle Your FLA Return 2026
- Frequently Asked Questions — FLA Return 2026
What is FLA return?
FLA full form: Foreign Liabilities and Assets. known as Annual Return on Foreign Liabilities and Assets
FLA Return is a mandatory annual disclosure filed directly with the Reserve Bank of India. It captures the outstanding foreign investments — both inbound (FDI received) and outbound (ODI made) — that appear in an entity’s balance sheet as of 31st March of the relevant financial year.
Think of it as the RBI’s way of keeping a real-time picture of India’s international financial position. The data feeds into India’s Balance of Payments (BoP), the International Investment Position (IIP), and IMF surveys like the Coordinated Direct Investment Survey. In short, your filing matters at a national and global level.
The return is governed by A.P. (Dir Series) Circular No. 45 dated March 15, 2011, and all filings must now be made through the FLAIR (Foreign Liabilities and Assets Information Reporting) portal — no offline Excel sheets or email submissions are accepted anymore.
In simple terms: If your Indian company has received FDI (Foreign Direct Investment) or made ODI (Overseas Direct Investment), you must report it to the RBI every year through the FLA Return form.
Foreign Liabilities and Assets Return Applicability — Who needs to file?
Who must file the FLA return?
The following Indian-resident entities are mandatorily required to file the FLA Return if they have outstanding FDI or ODI as on 31 March 2026, or had it in any prior year:
| Entity Type | When It Applies |
| Private / Public Limited Companies | Received FDI in current or any previous year, OR made ODI abroad. |
| Limited Liability Partnerships (LLPs) | Received capital contribution or profit share from non-residents. |
| SEBI-registered Alternative Investment Funds (AIFs) | Any outstanding foreign assets or liabilities. |
| Partnership Firms | Received FDI or made ODI (RBI issues a dummy CIN for filing). |
| Public Private Partnerships (PPPs) | Any outstanding foreign investment position. |
📌Important Point for Older Investments
Even if you received FDI five years ago and have had no fresh inflows since, you are still required to file the FLA Return every year as long as the outstanding balance is on your books. It is not a one-time filing — it is annual.
Who does not need to file FLA return?
Companies Exempted from filing FLA return:
Not every company with foreign shareholders must file. The following are exempt from the FLA Return:
- Entities that have never received FDI or made ODI in any previous year (including the current year)
- Companies that have zero outstanding foreign assets or liabilities as of end-March of the reporting year
- Companies that issued shares to non-residents only on a non-repatriable basis (e.g., shares issued under Section 6(3)(b) of FEMA)
- Entities that received only share application money but have not yet allotted shares or received actual FDI
If you are unsure whether your entity qualifies, it is always safer to consult a FEMA compliance expert. Filing when not required is harmless; not filing when required can be costly. To know more, you can contact us here.
Due Dates & Deadlines For FLA Return 2026
| Milestone | Date | Notes |
| Financial year-end (reporting date) | 31 March 2026 | FLA captures position as of this date. |
| FLA Return filing deadline | 15 July 2026 | File on audited OR unaudited accounts. |
| Revised return (if unaudited) | 30 September 2026 | File revised return with audited figures. |
| Monitor RBI circulars for extension | June – July 2026 | RBI extended deadline to 31 July in 2025 — do not assume extension in 2026. |
⚠️ Pro Tip:
In 2025, the RBI extended the deadline from 15 July to 31 July. However, this is not guaranteed every year. Our strong advice: prepare and file by 15 July 2026 and treat any extension as a bonus — not a plan.
How to File the FLA Return — Step-by-Step Process
FLA Return filing happens through the FLAIR Portal — Foreign Liabilities and Assets Information Reporting system.
Portal URL: https://flair.rbi.org.in
Step 1: Register on FLAIR
- Visit https://flair.rbi.org.in
- Click on “Registration for New Entity Users”
- Fill the FLA User Registration Form
- Upload two documents: Verification Letter and Authority Letter
- Submit the form
After successful registration, a User ID and default password will be sent to the authorized person’s registered email.
Step 2: Login and Access the FLA Form
- Log in using your credentials
- Navigate to the FLA Return section
- The portal supports all major browsers — Chrome, Firefox, Internet Explorer
Step 3: Fill the FLA Form
The FLA Return has five most important sections, which need to be carefully filled as per the requirements:
| Section | What It Covers |
| I — Prefilled Information | Auto-filled: company name, PAN, CIN, head of institution’s email. Verify these are correct. |
| II — Contact Details | Details of the contact person: name, phone, email, designation, website, account closing date. |
| III — Foreign Liabilities | FDI received in India: non-resident equity, participating preference share capital, external commercial borrowings, trade credits, and other foreign liabilities. |
| IV — Foreign Assets | ODI made abroad: equity in overseas subsidiaries/JVs, debt securities under portfolio investment, other overseas financial assets. |
| V — Variation Report | Auto-generated from Sections III and IV. Shows year-on-year changes. Review carefully for accuracy before final submission. |
Note: Market value calculations for equity (both listed and unlisted entities) are automatically computed by the portal. You don’t need to calculate these manually.
Step 4: Submit and Get Acknowledgement
Once submitted, you’ll receive an acknowledgement from RBI. Keep this for your compliance records.
Special Cases Of FLA Return You Should Know
What if You’re an AIF?
AIFs (Alternative Investment Funds) need to register on FLAIR but currently cannot file online. Instead:
- Email flareturn@rbi.org.in after registration to request the latest Excel format
- Fill it and send it back to the same email
- You’ll receive email-based acknowledgement
What about GIFT City / IFSC entities?
Yes — entities registered under IFSC operating from GIFT City are required to file the FLA return if they have received foreign investment or hold overseas investment. No exemption applies here.
Account Closing Period Different from March?
You must still report data as on end-March, based on your internal assessment. You cannot report as per your own closing period if it differs from March.
Change in Entity Name, CIN, or Contact Details?
If your CIN has changed after the reporting year (March 31), use the old CIN for that reporting period. For changes in email ID, authorized person, or entity name — you need to deactivate your old account by emailing flareturn@rbi.org.in and then re-register on the portal.
Documents You Will Need Before Filing FLA (Foreign Liabilities and Assets) Return
Gather these before you log in to the FLAIR portal. Missing documents mid-filing can cause validation errors and delays.
- PAN of the company/LLP and CIN / LLPIN (for companies) or dummy CIN (for partnership firms)
- Financial statements — audited if available; provisional/unaudited if audit not yet complete
- Authority Letter — authorising the person filing the return (in RBI’s prescribed format)
- Verification Letter — confirming entity details (in RBI’s prescribed format)
- Shareholding pattern — showing non-resident equity percentage
- FDI details — investor names, country of residence, percentage holding, amount
- ODI details — details of overseas subsidiaries/JVs, equity and loan positions
- Previous year’s FLA Return — if filed, as reference for consistency
- Employee count and registered address
- OTP access to registered email / mobile for FLAIR portal login
Penalties for Non-Filing or Late Filing of FLA Return 2026
This is where businesses often get a rude shock. Non-filing or inaccurate filing of the FLA Return is treated as a violation of FEMA, 1999 (Section 13), and the penalties are significant:
🚨FEMA Penalty Structure for FLA Non-Compliance
| Type of Default | Penalty |
| Non-filing / late filing | Up to 3 times the amount involved in the contravention |
| If amount is unquantifiable | Up to ₹2,00,000 (₹2 lakh) flat penalty |
| Continuing default (each day) | ₹5,000 per day until compliance |
| Late Submission Fee (LSF) | ₹7,500 per return at the time of submission |
The RBI’s regional offices have the authority to compound contraventions without any upper limit. Early filing is always the safest and cheapest option.
How can Mercurius help in filing your FLA return?
Mercurius files your FLA Return on your behalf, so you don’t have to deal with the complexities of RBI compliance. Our team of experienced CA and CS professionals handles everything—from data preparation to accurate filing and timely submission. While we take care of your compliance, you can stay focused on running and growing your business operations without any stress.
Don’t Risk a FEMA Penalty — Let Mercurius Handle Your FLA Return 2026
Our FEMA and RBI compliance specialists manage the entire process — from data preparation and shareholding analysis to FLAIR portal submission and post-filing support. Accurate. On time. Hassle-free.
Book a first free consultation on – https://masllp.com/contact-us/
Quick Connect
Frequently Asked Questions — FLA Return 2026
Q: What is the FLA Return due date for 2026?
The FLA Return 2026 must be filed by 15 July 2026. If accounts are unaudited at that time, file provisional figures by 15 July and submit a revised return with audited figures by 30 September 2026. Watch RBI circulars in June–July 2026 for any potential extension.
Q: Where do I file the FLA Return?
All FLA Returns must be filed on the RBI’s FLAIR portal at https://flair.rbi.org.in. No offline Excel-based or email submissions are accepted (except AIFs, who can email flareturn@rbi.org.in).
Q: Does a dormant foreign subsidiary still require FLA filing?
Yes. Even if the overseas entity (subsidiary or JV) is dormant and not generating revenue, the Indian parent company must continue to report the outstanding ODI in its FLA Return.
Q: Is there a government fee for filing the FLA Return?
No, there is no government fee for the FLA Return submission itself. However, if filed late, a Late Submission Fee (LSF) of ₹7,500 per return applies at the time of belated submission.
Q: Does filing the FLA Return require a Digital Signature Certificate (DSC)?
No. The FLAIR portal does not require a DSC for FLA Return filing. Login credentials and OTP verification are sufficient.
Q: Can I file the FLA Return for multiple years if I missed past filings?
Yes, you can file belated returns for previous years. However, this is treated as a FEMA contravention and may be subject to compounding and penalties. It is strongly advisable to regularise past non-filings with guidance from a FEMA compliance expert.
Q: Is the data in the FLA Return kept confidential?
Yes. As per the RBI’s official FAQs (updated March 2026), entity-wise information provided in the FLA Return is kept confidential. Only consolidated aggregate data is released publicly by the Reserve Bank. Of India
