FLA Return Filing Online in India

FLA Return Applicability and Eligibility in India

FLA Return Filing is generally required for Indian companies, LLPs and other specified entities having qualifying outstanding Foreign Direct Investment (FDI) or Overseas Direct Investment (ODI) as of 31 March of the relevant financial year. Even if a business has not received fresh foreign investment during the year, it may still need to file the return if earlier investments remain outstanding.

Who Is Required to File an FLA Return?

• Private and Public Limited Companies: Companies having qualifying outstanding foreign investment.

• Limited Liability Partnerships (LLPs): LLPs with qualifying foreign capital contributions or overseas investments.

• Companies with Overseas Subsidiaries: Indian businesses holding qualifying investments in foreign subsidiaries or joint ventures. Read our FLA Return Filing Online 2026: RBI FLAIR Guide for more details.

• Startups with Foreign Funding: Startups with qualifying foreign investment outstanding at the financial year-end.

• Other Specified Entities: Certain partnership firms, AIFs and other entities covered by RBI reporting instructions.

When Is FLA Return Filing Not Required?

FLA Return Filing is generally not required when an entity has no qualifying outstanding FDI or ODI as of 31 March. Businesses holding only share application money without qualifying FDI or ODI are generally not required to file on that basis alone. Similarly, export payments from foreign customers do not automatically create an FLA filing obligation.

Example

ABC Private Limited received foreign investment in 2022, and the investor continued holding shares as of 31 March 2026. Even though no fresh investment was received during FY 2025–26, the company was generally required to file its FLA Return by 15 July 2026 because the qualifying foreign investment remained outstanding.

Documents Required for FLA Return Filing

Proper documentation is essential for preparing an accurate FLA Return. The RBI requires businesses to report financial and investment information relating to the relevant financial year, so companies should maintain records supporting their foreign liabilities and assets.

The documents required may differ depending on whether the business has received foreign investment, made overseas investments or both. Preparing the relevant details before starting the filing process can reduce errors and make online submission easier.

1. Company or LLP registration documents

• Certificate of Incorporation or LLP registration details.

• PAN of the reporting entity.

• Corporate Identification Number (CIN) or LLP identification details, where applicable.

• Registered office address and official contact information.

• Details of the authorised person responsible for filing.

2. Financial statements and accounting records

• Balance sheets for the relevant reporting periods.

• Profit and loss statements.

• Paid-up capital and reserves information.

• Audited financial statements, if available.

• Provisional financial statements where permitted.

3. Foreign Direct Investment documents

• Foreign investor details and shareholding information.

• Share allotment records and investment agreements.

• Relevant FC-GPR reporting records.

• FC-TRS records, where foreign investment has changed through share transfers.

• Records of foreign capital contributions received by LLPs.

4. Overseas investment documents

• Details of foreign subsidiaries and joint ventures.

• Overseas shareholding and investment records.

• Relevant overseas financial information.

• ODI reporting records and supporting remittance documents.

• Other information needed to determine reportable foreign assets.

5. FLAIR portal registration documents

• Verification Letter, as applicable.

• Authority Letter for the person authorised to report.

• Relevant PAN and identity information required during registration.

• Registered email address and authorised contact details.

6. Previous filing records

Companies that have submitted the FLA Return in earlier years should maintain copies of their previous returns and acknowledgements. These records help identify changes in foreign shareholding and reconcile financial information from one year to another.

Important: Ordinary FLA filing does not generally require uploading the complete balance sheet and profit and loss account as attachments. However, the company should maintain these documents to support the figures reported to the RBI.

FLA Return Filing Process on RBI FLAIR Portal

FLA Return Filing is completed online through the RBI's FLAIR portal. The process includes entity registration, preparation of financial information, reporting of relevant foreign investments and final electronic submission.

Businesses should confirm their filing eligibility and gather the required documents before starting the process. A correctly prepared return helps ensure that the foreign liabilities and assets reported are consistent with the company's records.

Step 1. Check FLA Return applicability

The first step is to determine whether the entity is required to submit the FLA Return. The company should review its foreign shareholding, overseas investments and outstanding qualifying FDI or ODI as of 31 March.

Step 2. Register on the RBI FLAIR portal

Visit the official RBI FLAIR portal and access the entity registration facility. Enter the required identification and authorised-person information. Existing users should use their registered account instead of creating a duplicate registration.

Step 3. Prepare registration documents

Complete the prescribed entity registration requirements and arrange the Verification Letter, Authority Letter and other documents requested by the portal.

Step 4. Log in to the FLAIR portal

Once registration is completed and credentials are available, the authorised user can log in and access the online FLA Return facility.

Step 5. Select the relevant financial year

Choose the financial year for which the return must be filed. For FY 2025–26, the reporting covers the applicable foreign investment positions as of 31 March 2026, along with comparative details for 31 March 2025.

Step 6. Enter financial and investment information

Provide the required corporate details, financial information, foreign liabilities and foreign assets. The figures should be reconciled with the company's books and foreign investment records.

Step 7. Review and validate the FLA Return

Before submission, verify the reported investments, ownership information, financial figures and other relevant details. Any inconsistencies should be corrected using the applicable portal instructions.

Step 8. Submit and preserve the acknowledgement

After successful submission, download or save the electronic acknowledgement generated by the FLAIR portal. The acknowledgement is important evidence of filing and should be maintained with the company's compliance records.

FLA Return Due Date and Reporting Requirements

The Reserve Bank of India (RBI) requires eligible entities to file the Annual Return on Foreign Liabilities and Assets (FLA Return) by 15 July every year through the FLAIR portal. The return reports qualifying foreign investments outstanding as of 31 March, along with comparative financial information for the previous year.

FLA Return Filing is a separate annual compliance requirement. Even if a company has already filed Form FC-GPR or other RBI returns, it may still need to submit its FLA Return. For more details, read our article on FLA Return Filing and Due Dates with the Checklist.

FLA Return Due Dates

Can an FLA Return Be Filed Without Audited Financial Statements?

Yes. If audited financial statements are unavailable before 15 July, businesses can file the FLA Return using provisional or unaudited figures. Once audited statements become available, they should request permission through the FLAIR portal to revise the return and submit the updated financial information after RBI approval.

What Happens If the FLA Return Due Date Is Missed?

Missing the FLA Return deadline may result in FEMA non-compliance. Businesses should verify their pending reporting obligations, seek permission for delayed filing through the applicable RBI process and address any Late Submission Fee or other regulatory consequences, where applicable. For FY 2025–26, the ordinary deadline of 15 July 2026 has already passed. Entities with pending filings should take corrective action without further delay.

Information Required in the FLA Return Form

The FLA Return collects information about an entity's financial position, foreign investments and outstanding foreign assets and liabilities. Businesses must provide accurate details through the RBI FLAIR portal to meet their annual reporting requirements.

The FLA Return generally contains five main sections:

Section I – Identification Particulars

This section includes basic information about the reporting entity, such as its legal name, PAN, CIN or other applicable identification details, registered address, contact person and nature of business. These details should match the company's official registration records.

Section II – Financial Details

This section contains financial information about the reporting entity, including:

• Paid-up capital and shareholding details

• Reserves and surplus

• Profit and loss information

• Sales, purchases and other prescribed financial particulars

Businesses should use accurate financial records for the relevant reporting periods.

Section III – Foreign Liabilities

This section records the entity's outstanding financial liabilities to non-residents. It may include qualifying Foreign Direct Investment (FDI), portfolio investment and other reportable foreign liabilities. Companies should verify foreign investor details and ownership information before submitting the return.

Section IV – Foreign Assets

This section covers financial assets held outside India, including qualifying Overseas Direct Investment (ODI) in foreign subsidiaries or joint ventures. Businesses should maintain accurate overseas investment records and report the relevant foreign asset positions.

Section V – Variation Report

The Variation Report helps identify changes in foreign liabilities and assets between reporting periods. Companies should review significant differences and ensure that their financial records support the reported figures.

Important Reporting Requirements

• Accurate information: Financial figures and foreign investment records should match the applicable reporting requirements.

• Correct classification: Domestic assets and liabilities should not be reported as foreign positions merely because they are denominated in foreign currency.

• Record verification: Companies should review foreign shareholding and overseas investment information before filing.

• Annual compliance: Businesses can also explore our FEMA Compliance Services to understand related RBI reporting obligations and ongoing compliance requirements.

Compliance Calendar LLP assists businesses with FLA Return preparation, financial data verification and RBI reporting requirements to support accurate and timely filing.

FLA Return Filing Fees, Late Fees and Penalties in India

FLA Return Filing through the RBI FLAIR portal does not involve a standard government filing fee when submitted within the prescribed deadline. However, businesses may incur professional charges for preparing financial information, reviewing foreign investment records and completing the return. Delayed filing may also attract a Late Submission Fee (LSF) or other regulatory consequences under FEMA, depending on the circumstances.

FLA Return Filing Charge

Late Submission Fee for FLA Return

Under the RBI's Late Submission Fee provisions, Rs 7,500 per delayed FLA Return is prescribed for the relevant category of periodic reporting delays. The availability of this option and the procedure for regularising a delayed return depend on the applicable RBI requirements.

Businesses with pending filings can seek FEMA Advisory Services to understand the appropriate corrective procedure and reporting obligations.

Penalties for Non-Filing of FLA Return

Failure to file a mandatory FLA Return may result in regulatory action under the Foreign Exchange Management Act, 1999. Under Section 13 of FEMA, penalties may extend to three times the amount involved where the contravention is quantifiable, or up to Rs 2 lakh where it is not quantifiable. A continuing contravention may attract an additional penalty of up to Rs 5,000 per day after the first day.

These are statutory maximum limits and are not automatic penalties for every delayed FLA Return. Companies with missing filings, incorrect investment records or other compliance concerns may consider FEMA Due Diligence to identify discrepancies and determine the appropriate corrective steps.

How to Avoid FLA Return Filing Delays

• Check applicability early: Confirm whether the entity has qualifying outstanding FDI or ODI.

• Maintain accurate records: Keep foreign shareholding, financial and investment information updated.

• Prepare financial statements: Use provisional figures where permitted if the statutory audit is incomplete.

• Preserve filing acknowledgements: Maintain previous RBI returns and relevant correspondence.

• Review pending filings: Identify and address delayed or incomplete returns promptly.

Compliance Calendar LLP assists businesses with FLA Return preparation, delayed filing reviews, RBI reporting requirements and related FEMA compliance matters. Our team helps companies understand their reporting responsibilities and prepare the necessary documents.

Revised FLA Return and Previous Year Filing

Businesses may need to revise an already submitted FLA Return when audited financial statements become available or errors are identified in foreign investment details. The RBI allows eligible entities to revise previous returns or file returns for earlier financial years after obtaining the required approval through the FLAIR portal.

When Is FLA Return Revision Required?

• Audited financial figures differ from provisional figures.

• Foreign investor shareholding details were reported incorrectly.

• Overseas investment information needs correction.

• Financial figures were entered incorrectly.

• Earlier financial years' mandatory FLA Returns were not filed.

Process for Revised or Previous Year FLA Filing

1. Log in to the RBI FLAIR portal.

2. Open the applicable FLA form or Multiple Year Enable facility.

3. Select the financial year requiring revision or delayed filing.

4. Submit the request for RBI approval.

5. After approval, complete or revise the relevant return.

6. Submit the return and preserve the acknowledgement.

What If the FLA Return Was Not Filed in Previous Years?

Companies that missed earlier FLA Return deadlines should review their foreign investment records and identify the years for which reporting was mandatory. They must follow the prescribed RBI approval process before submitting previous-year returns. Applicable Late Submission Fees or other FEMA consequences should be examined separately.

Compliance Calendar LLP assists businesses with revised FLA Returns, previous-year filing, financial data reconciliation and RBI reporting requirements.

FLA Return vs FC-GPR, FC-TRS and ODI Reporting

Businesses involved in foreign investments may need to file different RBI reporting forms depending on the transaction. The FLA Return reports qualifying outstanding foreign financial liabilities and assets annually, while FC-GPR and FC-TRS are used for specific foreign investment transactions. Overseas investments may also require separate ODI reporting.

Difference Between FLA Return and Other RBI Reporting Forms

Businesses involved in foreign share allotments or transfers can read our guide on FC-GPR vs FC-TRS 2026: When to File Each Form? to understand their respective reporting requirements.

FLA Return and FC-GPR

Form FC-GPR generally applies when an Indian company issues qualifying equity instruments to a non-resident investor. The FLA Return separately reports the outstanding foreign investment position at the financial year-end.

For example, if a company receives foreign investment and issues shares in November 2026, FC-GPR reporting may be required. If the investment remains outstanding on 31 March 2027, the company may also need to file its FLA Return for FY 2026–27.

FLA Return and FC-TRS

Form FC-TRS applies to specified transfers of equity instruments between residents and non-residents. Such transactions may change foreign ownership in an Indian company. Where applicable, the updated investment position must also be reflected in the annual FLA Return.

FLA Return and ODI Annual Performance Report

Indian businesses with qualifying overseas investments may need to file an Annual Performance Report (APR) under the applicable ODI regulations. The APR reports information relating to overseas investments, whereas the FLA Return reports annual foreign liabilities and assets. Filing an APR does not replace the FLA Return, where both are applicable.

Why Separate RBI Reporting Is Important

Completing FC-GPR, FC-TRS or ODI reporting does not automatically fulfil the annual FLA Return requirement. Businesses should review each filing separately and maintain consistent foreign investment records.

Compliance Calendar LLP assists companies with RBI reporting, foreign investment documentation and annual FEMA compliance to help them meet the applicable filing requirements.

Why Choose Compliance Calendar LLP for FLA Return Filing?

FLA Return Filing requires careful review of foreign investment information, financial records and applicable RBI reporting requirements. A reporting error or missed deadline can create additional compliance work for a business, especially when it has several foreign investors or overseas subsidiaries.

Compliance Calendar LLP provides professional assistance to Indian companies, startups, LLPs and other eligible entities involved in foreign investment reporting. Our services are designed to help businesses understand their filing obligations and complete the relevant reporting procedures accurately.

We assist businesses from the initial applicability review to the preparation and submission of their FLA Returns.

Our FLA Return Filing services

• FLA Applicability Review: We help determine whether an entity is required to submit the FLA Return based on its qualifying foreign investments.

• RBI FLAIR Registration: Assistance with entity registration, authorised-user details and required documentation.

• Financial Information Review: Support in reviewing relevant financial statements and foreign investment positions.

• FLA Return Preparation: Assistance in completing the prescribed financial and investment reporting sections.

• Online Filing Support: Guidance and assistance with submitting the return through the RBI FLAIR portal.

• Previous Year Filing: Support in reviewing pending annual returns and applicable delayed reporting procedures.

• Revised FLA Return: Assistance with identifying and correcting previously reported information through the prescribed process.

• Related FEMA Services: Professional assistance with FC-GPR, FC-TRS, EMF and SMF reporting, ODI requirements and other relevant FEMA compliances.

How we help your business

Our team reviews the relevant documents, identifies reporting requirements and assists with preparing the necessary information. Where businesses have already completed foreign investment transactions, we help them understand how those records relate to annual RBI reporting.

We also assist clients in identifying previous-year filing gaps and understanding the appropriate process for correcting or completing delayed reporting.

Whether your company has recently received foreign investment or has maintained overseas investment positions for several years, Compliance Calendar LLP can support your annual FLA Return filing and related FEMA compliance requirements.

Contact Compliance Calendar LLP for FLA Return Filing assistance and RBI reporting support.