The FLA (Foreign Liabilities and Assets) return is the annual census every Indian entity with foreign investment must file with RBI – standard due date 15 July, covering the position as on 31 March. Unlike FC-GPR and FC-TRS, which report transactions, the FLA reports stock: what the entity owes to and owns abroad. It is the FEMA filing most often missed by subsidiaries and startups – usually discovered years later during due diligence.
Who must file – the exact test
| Element | Test |
|---|---|
| Trigger | Entity has received FDI and/or made overseas direct investment in any year and holds outstanding FDI/ODI on its balance sheet as on 31 March of the reporting year |
| Covered entities | Companies, LLPs, and “others” – SEBI-registered AIFs, partnership firms, PPPs |
| Key nuance | The test is the outstanding position at end-March, not historical receipt. Past FDI fully exited by March = no filing |
Who does NOT need to file
- No outstanding FDI/ODI as on 31 March – no filing, and no nil return either;
- Only share application money pending (nothing allotted) – not required;
- Investment held purely on non-repatriation basis (Schedule IV NRI/OCI money) – not treated as foreign investment, no FLA;
- All foreign shares transferred to residents before year-end – file for the years it was outstanding, then stop.
How to file – the FLAIR portal
- 1. Register at flair.rbi.org.in (Registration for New Entity Users) uploading the verification letter and authority letter in RBI formats – separate from the FIRMS login;
- 2. RBI emails the user ID/password;
- 3. File section by section: identification, financials, foreign liabilities (equity, other capital – including inter-company payables to the parent), foreign assets, variance report;
- 4. Accounts not audited yet? File on provisional figures by the due date;
- 5. If audited numbers differ, request revision on the portal and refile by 30 September.
Miss it, and…
| Stage | Consequence |
|---|---|
| Late filing | LSF: flat ₹7,500 per return (FLA sits in the flat-fee row of the LSF matrix) |
| Beyond 3 years | LSF unavailable – compounding: indicative ₹10,000 per delayed return under RBI’s computation matrix |
| Worst case | Adjudication under FEMA section 13: penalty up to 3x the amount involved (or ₹2 lakh where not quantifiable) plus ₹5,000/day continuing |
| Practical pain | Missed FLAs surface in due diligence – funding rounds and exits stall while years of returns are regularised |
FLA vs the other FEMA filings
| FLA | FC-GPR / FC-TRS / DI | |
|---|---|---|
| Reports | Annual position (stock) | Individual transactions (flows) |
| Portal | FLAIR (direct to RBI) | FIRMS (via AD bank) |
| Due | 15 July + 30 Sept revision | 30/60 days per event |
| Substitutes the other? | Never – filing FLA does not cure a missed FC-GPR, and vice versa | |
July deadline looming – or years missed?
We prepare and file the FLA from your financials, and regularise past-year gaps through LSF or compounding.
Talk to My Cloud AccountantFrequently asked questions
Is the FLA return due date 15 July every year?
Yes – 15 July for the position as on the preceding 31 March, with a revision window to 30 September for audited figures. RBI occasionally extends by portal announcement, as it did to 31 July for the 2026 season.
Can we file FLA on unaudited accounts?
Yes – file on provisional figures by the due date, then request revision on FLAIR and refile with audited numbers by end-September if they differ. Waiting for the audit is not a valid reason to miss July.
Does a company with only NRI non-repatriation investment file FLA?
No – investment on non-repatriation basis is not treated as foreign investment for the FLA. If that is the only foreign-origin capital, no return is required.
Is there a nil FLA return?
No such obligation – if there is no outstanding FDI/ODI as on 31 March, simply do not file. The nil-return concept applies to some other filings but not the FLA.
Based on the FEM (Mode of Payment and Reporting of Non-Debt Instruments) Regulations 2019, RBI FLA FAQs (updated March 2026) and the FLAIR portal. Last reviewed: July 2026.