Every year, quietly, on 15 July, one of the most-missed FEMA deadlines falls due. The FLA return is an annual census, not a transaction filing — which is exactly why companies forget it. If your company has ever received foreign investment, or made one abroad, this filing is yours. Even if nothing happened this year. Even if the company is dormant.
What the FLA return is
The Foreign Liabilities and Assets (FLA) return is the RBI's annual snapshot of cross-border investment positions. It reports your foreign liabilities (FDI received, on whatever date) and foreign assets (overseas direct investment made) as they stand on 31 March. Unlike FC-GPR — which is triggered by a share allotment — the FLA return is triggered simply by the calendar.
Who must file
The net is wider than most assume. The return applies to companies, LLPs, AIFs and partnership firms that have, in any year:
- received foreign direct investment, or
- made overseas direct investment (ODI),
and that have foreign assets or liabilities outstanding on 31 March of the reporting year. The test is the balance sheet, not the year's activity. Three situations that still require filing:
- No transactions this year. The FDI came in 2019 and nothing has moved since? File. The position is still outstanding.
- The company is dormant. No revenue, no operations, no employees — irrelevant. If foreign shareholding sits on the books, file.
- The foreign holding is small. There is no materiality threshold. Any outstanding foreign investment triggers the return.
The only clean exemption: nothing outstanding on 31 March — for example, the foreign shares were fully transferred to residents before the year-end.
The deadline and the FLAIR portal
The return is due by 15 July each year and is filed on the RBI's FLAIR portal (flair.rbi.org.in). First-time filers must create an entity login on FLAIR before they can file — allow a few working days for that, not a few hours on 14 July.
Audited accounts are not a prerequisite. If your audit is not complete by 15 July — common, since most Indian companies finalise later in the year — you file with provisional figures by 15 July and submit a revised return by 30 September based on the audited numbers. "The audit isn't done" is not a reason to miss the deadline; the RBI designed around it.
What you need to file
- Financial statements (audited or provisional) as on 31 March;
- The equity position: paid-up capital, foreign shareholding percentage and the non-resident holders' details;
- Other foreign liabilities — loans from the foreign parent or group, trade credits;
- Any overseas investments the entity itself holds;
- Valuation workings — the return asks for the foreign holding at market value, computed per the return's own formula for unlisted companies.
Where the FLA sits in the FDI reporting stack
It helps to see the three RBI filings as answering different questions:
| Filing | Trigger | Deadline |
|---|---|---|
| FC-GPR | Shares allotted to a non-resident | 30 days from allotment |
| FC-TRS | Shares transferred between a resident and a non-resident | 60 days |
| FLA return | Foreign investment outstanding on 31 March | 15 July, every year |
The first two are event filings — done once per transaction. The FLA is the standing annual obligation that continues long after the events stop. That is also why the RBI cross-checks them: an FC-GPR on record with no FLA returns behind it is an easy flag.
Practical notes before you file
- Register on FLAIR early. The entity-user registration is a one-time step, but it needs authorised-person details and verification. Do not leave it for deadline week.
- No CA certification is required. The return is self-reported by the entity — but keep the valuation workings and shareholding reconciliation on file, because the figures feed future filings and due diligence.
- Be consistent with FC-GPR history. The shareholding pattern you report should reconcile with what was reported at each allotment. Discrepancies invite questions years later.
- Provisional first, revised later, is normal. Filing on provisional numbers by 15 July and revising by 30 September after audit is the designed path, not a concession to chase.
What missing it costs
Non-filing is a contravention under FEMA. Late reporting attracts a Late Submission Fee of ₹7,500; left unresolved, a contravention can escalate to a penalty of up to three times the amount involved — or ₹2 lakh where the amount is not quantifiable, plus ₹5,000 per day for a continuing default. There is a quieter cost too: a missing FLA history surfaces at the worst moments — in due diligence for a funding round, or when the AD bank reviews the file for a remittance.
The short version
FDI or ODI outstanding on 31 March = FLA return due 15 July, on the FLAIR portal. Dormant or transaction-free years do not exempt you. Unaudited? File provisional by 15 July, revise by 30 September. See India entry, FEMA & FDI services for the nature of services.
The FLA return is missed for one reason: nothing happens during the year to remind anyone. Put it on the compliance calendar the day the first FDI arrives, and it never becomes a problem.
New to Indian FDI compliance altogether? Start with our guides on opening a subsidiary in India and the FDI automatic and approval routes. And if the 15 July deadline is already close, you can reach the firm here.
Frequently asked questions
Yes. The test is not activity — it is whether foreign investment or overseas investment is outstanding on the balance sheet as on 31 March. A company that received FDI years ago and has done nothing since must still file, every year, as long as that investment remains on its books.
15 July every year, reporting data as on 31 March. If the accounts are unaudited by then, file with provisional figures by 15 July and revise the return by 30 September once the audit is complete.
You still file, as long as previously received FDI or ODI remains outstanding on 31 March. The return reports positions, not just transactions. You are exempt only if there is nothing outstanding on the balance-sheet date.
Non-filing is a contravention under FEMA. Late reporting attracts a Late Submission Fee of ₹7,500, and unresolved contraventions can escalate to penalties of up to three times the amount involved — or ₹2 lakh where the amount is not quantifiable, plus ₹5,000 per day for a continuing default.