FLA Return Filing Under FEMA (2026)

Last updated: 30 July 2026

Quick Answer: The FLA (Foreign Liabilities and Assets) Return is an annual return that Indian entities holding foreign assets or liabilities must file with the Reserve Bank of India under FEMA, reporting their position as on 31 March. For the financial year 2025-26, the Reserve Bank has extended the due date to 31 July 2026, filed online through the FLAIR portal.

Any company or LLP (limited liability partnership) incorporated and registered in India and any other eligible entity having foreign investments or having made investments outside India has an obligation under the Foreign Exchange Management Act, 1999 (FEMA) to file FLA return as on 31st March every year. The filing of FLA Return is compulsory in India as per FEMA and RBI regulations. This guide contains details on who qualifies for filing, available exemptions, deadlines for FLA Return and the consequences for not filing.

What is the FLA Return?

FLA Return is a yearly return which is filed before the Reserve Bank of India that shows the amount of foreign liabilities and assets owed by Indian residents as on the 31st of March of relevant financial year, FLA Return is said to be a position return meaning that the outstanding amounts as on date are to be reported rather than transactions entered during the year.

Why does the RBI require the FLA Return?

The aim is to introduce macro-prudential measures. The data provides the Reserve Bank of India the ability to determine India's foreign investment position, which allows the RBI to monitor foreign investments as laid out in the Reserve Bank's FLA guidance. Furthermore, since the information is aggregated into a national statistics file, precision and promptness become more crucial than that of every filing institution.

Who is required to file the FLA Return?

An Indian resident entity needs to file the FLA Return if it has received Foreign Direct Investment (FDI) at any time during the previous or current financial year or has made Overseas Direct Investment (ODI) in a foreign entity and if the balance of borrower's foreign liabilities or the value of the borrower's foreign assets is greater on the last date of the financial year which is 31st March of that financial year.

Who is not required to file the FLA Return?

In most cases, an entity does not need to submit an FLA Return if it has only one of the following criteria.

• Foreign Portfolio Investment (FPI);
• External Commercial Borrowings (ECB); or
• No outstanding foreign assets or liabilities as on 31 March.

What is the FLA Return due date for FY 2025-26?

FLA Return needs to be filled out for the period ending on 31st March for every financial year and submitted on or before 15th July every year. However, RBI has announced a new deadline of the same i.e. 31st July 2026 for the FLA return for the FY 2025-26.

What if the audited accounts are not ready by the due date?

A company may file the return using unaudited financial statements if it does not have the audited financial statements ready on time. This provisional measure ensures that the deadline is maintained, while allowing amendments to the figures once the accounts are finalised.

What information does the FLA Return require?

The return draws directly from the entity's financial statements. It generally includes:

• Foreign equity participation;
• Outstanding foreign liabilities;
• Overseas investments;
• Financial information from the balance sheet;
• Profit and loss details;
• Investments in foreign subsidiaries, associates and branches;
• Details of foreign investors and ownership.

How is the FLA Return filed on the FLAIR portal?

The submission of FLA return has been done easily through the RBI FLAIR (Foreign Liabilities and Assets Information Reporting) portal which enables registered companies to complete their registration as well as create their returns online. Generally, this includes the following steps:

1. Register the entity on the FLAIR portal and create login credentials.
2. Verify the entity's identification and constitution details.
3. Enter the foreign liabilities, foreign assets and financial information as on 31 March.
4. Validate the data against the portal's checks.
5. Submit the return and retain the system acknowledgement.
6. Direct all queries to the email flareturn@rbi.org.in (changed from the earlier surveyfla@rbi.org.in).

What are the penalties for not filing the FLA Return?

It is compulsory to file the FLA Return according to FEMA guidelines. Any delay in submission, non-filing or incorrect information can cause penalties as stated under FEMA rules. To deal with such issues, the Reserve Bank has come out with a Late Submission Fee (LSF) procedure so that the entity can regularise their submissions without incurring a compounded penalty as prescribed by Section 13(1) of the Foreign Exchange Management Act, 1999.

Common mistakes to avoid with the FLA Return

Most FLA defaults are avoidable and stem from a handful of recurring errors:

• Assuming exemption without checking balances. A single outstanding foreign asset or liability as on 31 March brings the entity into scope, even if no transaction occurred during the year.
• Waiting for audited accounts and missing the deadline. The provisional route, using unaudited figures, preserves the due date; the return can be revised once the audited statements are ready.
• Reporting figures that do not reconcile. Data that does not match the financial statements is the most common trigger for a revised filing.
• Treating the FLA as a one-time filing. It is an annual obligation for as long as foreign assets or liabilities remain outstanding.

How to keep FLA and other FEMA filings on track

The Return of the FLA is not often lacking when it comes to complexity. However, it does show some problems with visibility: you cannot know your due date, the financial statements do not add up, or a company mistakenly thinks it is exempt. In case a company has multiple entities and some overseas investments, managing the deadlines in reporting becomes laborious.

How does a compliance platform help with the FLA Return?

The FLA report is handled by the compliance management system, which makes certain that deadlines are kept and a designated person is assigned to file the FLA. The program reminds users well ahead of the 31 July deadline and retains the filing acknowledgement as evidence of compliance. LexComply does not submit FLA filings to the Reserve Bank of India, as it only helps users with meeting compliance deadlines. Firms need to determine whether the compliance rules apply to them, check the legislation concerning the activities they conduct, and request legal advice if necessary. Companies intending to go foreign must also take into account their obligations related to registration and licensing for making an FLA report.

Legal Disclaimer

This article is general information on FEMA reporting requirements and does not constitute legal advice. Entities should verify their specific FLA Return obligation against the current RBI guidance and, where necessary, seek professional advice.

Frequently Asked Questions

What is the full form of FLA Return?

FLA stands for Foreign Liabilities and Assets. The FLA Return is an annual return that reports an Indian entity's outstanding foreign liabilities and foreign assets as on 31 March to the Reserve Bank of India under FEMA. It is a position-based return, filed electronically through the FLAIR portal.

What is the FLA Return due date for FY 2025-26?

The standard due date is 15 July following the financial year that ends on 31 March. For the financial year 2025-26, the Reserve Bank of India has extended the due date to 31 July 2026. The return is submitted electronically through the RBI's FLAIR portal.

Can the FLA Return be filed with unaudited financial statements?

Yes. If audited financial statements are not available by the due date, the entity may file the return using unaudited figures and revise it later, once the audited statements are ready. This provisional route preserves the deadline while allowing the figures to be corrected on finalisation of the accounts.

Is the FLA Return required if a company has received only Foreign Portfolio Investment?

Generally, an entity that has only Foreign Portfolio Investment, only External Commercial Borrowings, or no outstanding foreign assets or liabilities is not required to file on that basis alone. The obligation should still be evaluated carefully, because a single outstanding balance can bring the entity into scope.

What is the penalty for late filing of the FLA Return?

A delay can be regularised through a Late Submission Fee of ₹7,500 per return, available up to 3 years from the due date. Beyond that window, or for non-filing and incorrect filing, penalties under Section 13(1) of FEMA can apply, including day-wise charges for a continuing default.