FLA Return, RBI's annual foreign-investment filing.

FLA Return is mandatory under FEMA Master Direction on Reporting under Foreign Exchange Management Act, for every:

• Indian company that has received FDI (inbound foreign equity investment) in the current or any previous FY AND still has outstanding foreign liability (foreign-shareholder balance) at the end of the FY.
• Indian company that has made ODI (outbound overseas investment) in the current or any previous FY AND still has outstanding foreign asset at the end of the FY.
• LLP with foreign capital contribution.
• AIF, Partnership firm, Public Private Partnership with foreign liabilities / assets.

Even if there is no fresh transaction in the current FY, if the opening balance of foreign liability / asset exists, FLA Return is mandatory.

Exempt (no FLA Return required):

• Companies with no foreign shareholder and no overseas investment.
• Companies where all foreign shareholding has been fully exited (nil opening balance for the FY).
• Non-reporting companies specifically identified by RBI.

Due date: on or before 15 July of the year following the FY. For FY 2024-25, due by 15 July 2025. For FY 2025-26, due by 15 July 2026.

If audited financial statements are not available by 15 July, the FLA Return can be filed with provisional (unaudited) numbers — a revised FLA Return with audited numbers must then be filed within 30 days of signing of audited financials.

Filing route:

1. FLA Return filed on the FLAIR portal (RBI's Foreign Liabilities and Assets Information Reporting system) at flair.rbi.org.in.
2. First-time users register on the portal with company's PAN + entity type + authorised person details.
3. Fill the online FLA Return form with company's shareholding pattern, foreign shareholders' details, outbound investments, equity + reserves + surplus, borrowing, assets.
4. Attach supporting documents: audited balance sheet (or provisional), auditor's report, share capital register.
5. Submit with DSC of the authorised signatory.
6. Download acknowledgement.

Core sections of FLA Return:

• Section 1: identification details (PAN, CIN, incorporation date, main activity, SBI RRN if applicable).
• Section 2: equity position — paid-up capital, foreign shareholder equity breakdown, resident shareholder equity. End-of-FY numbers.
• Section 3: foreign direct investment inward — foreign shareholder-wise paid-up equity, country of residence, breakup of equity, preference shares, convertible instruments.
• Section 4: outbound direct investment — details of overseas subsidiaries / JVs with equity + loans given.
• Section 5: other foreign liabilities — External Commercial Borrowings (ECBs), trade credit, foreign bank loans.
• Section 6: foreign assets — overseas bank accounts, foreign securities, loans given to foreign parties.
• Section 7: income & dividends — dividend paid to foreign shareholders in FY, dividend received from overseas subsidiaries.

• FEMA compounding: non-filing is a FEMA breach under Section 13. Compounding application can be filed voluntarily to pay reduced penalty (approximately INR 10,000-50,000 per year of non-filing, scaling with company size).
• Compounding + penalty: for persistent non-filing, RBI can impose compounding fee + penalty up to 3 times the amount involved.
• Operational: AD banks may hesitate to process future foreign remittances (inward FDI or outward ODI dividend repatriation) if FLA Return history is non-compliant.
• Diligence red flag: in M&A diligence, future FDI, future ODI, auditor review — FLA Return non-compliance surfaces and must be fixed.

Clean-up: file all missed FLA Returns for prior years (if the data can be reconstructed), then apply for compounding on FEMA breaches. Typical compounding timeline: 90-180 days from application to RBI order.

Last updated: 2026-10-12.