The Foreign Liabilities and Assets Return, commonly known as the FLA Return, is an annual return filed with the Reserve Bank of India under the Foreign Exchange Management Act, 1999.

It reports an Indian entity’s outstanding foreign liabilities and foreign assets, including eligible foreign direct investment received in India and overseas direct investment made outside India. The information is used by the RBI for compiling India’s balance of payments and international investment position.

The FLA Return may be applicable to Indian-resident entities that have outstanding inward foreign direct investment or overseas direct investment, including:

• Companies
• Limited Liability Partnerships
• SEBI-registered Alternative Investment Funds
• Partnership firms
• Proprietary firms
• Public Private Partnerships
• Other eligible Indian-resident entities

Applicability is determined based on the foreign investment position as at the end of March of the reporting year or the immediately preceding year.

The FLA Return must generally be filed with the RBI on or before 15 July every year for the financial year ending on the immediately preceding 31 March.

For example, the FLA Return for the financial year ending 31 March 2026 is ordinarily due by 15 July 2026.

Yes. Where audited financial statements are not available by 15 July, the entity should file the FLA Return using provisional or unaudited financial figures within the prescribed due date.

Once the audited financial statements become available, the entity should obtain permission through the FLAIR portal and submit a revised return using the audited figures. Revision is required irrespective of the amount or percentage of variation between the provisional and audited figures.

The FLA Return is filed electronically through the RBI’s Foreign Liabilities and Assets Information Reporting portal, commonly known as the FLAIR portal.

A new entity must first register on the portal by providing the prescribed details and uploading the verification and authority letters. After registration, login credentials are sent to the authorised person’s registered email address, following which the return can be prepared and submitted online.

The information generally required includes:

• Entity identification and registration details
• Audited or provisional financial figures
• Paid-up capital and reserves
• Details of non-resident shareholders
• Country-wise foreign investment details
• Percentage of foreign shareholding
• Details of overseas subsidiaries and joint ventures
• Foreign receivables and payables
• Loans, trade credit and other foreign liabilities or assets
• Previous year’s FLA Return information
• Details of disinvestment or changes in foreign investment

Balance sheets and profit and loss statements are not required to be uploaded with the return, although the relevant figures must be correctly reported in the online form.

A Nil FLA Return is generally not required where the entity has no outstanding inward FDI or outward ODI as at the end of March of both the reporting year and the immediately preceding year.

However, because the FLA Return captures data for two financial years, an entity may still be required to file the return where foreign investment was outstanding at the end of the previous year, even though no investment remains outstanding at the end of the current reporting year.

An entity that has received only share application money is generally not required to file the FLA Return where it does not have any outstanding inward FDI or outward ODI as at the end of March of the reporting year.

The applicability should be reconsidered once shares or other eligible equity instruments are issued to the non-resident investor.

Yes. An entity may revise a previously submitted FLA Return after obtaining approval from the RBI through the FLAIR portal.

An entity may also file an FLA Return for an earlier year in which the return was applicable but not filed. RBI approval is required, and delayed filing may attract the applicable late-submission or penalty provisions under FEMA.

The FLA Return is also separate from the Annual Performance Report filed in relation to overseas investment. Where both returns are applicable, filing one does not replace the requirement to file the other.

Failure to file the FLA Return within the prescribed time is treated as a violation of FEMA and may attract late-submission fees, penalty or compounding proceedings.

For delayed filing, the entity may be required to coordinate with the Foreign Exchange Department of the RBI’s Regional Office having jurisdiction over its registered office. Incorrect information should be corrected by obtaining approval and filing a revised return through the FLAIR portal.

Professional FLA Return filing services can assist with:

• Examining the applicability of the return
• Registering the entity on the FLAIR portal
• Reviewing foreign investment records
• Preparing foreign asset and liability details
• Reconciling figures with financial statements
• Reporting FDI and ODI positions correctly
• Filing provisional and revised returns
• Regularising delayed filings
• Coordinating for late-submission fee requirements

Maintaining RBI filing acknowledgements and supporting records