FLA Return: RBI Due Date 15 July, FLAIR & Late Fee
FLA return: every Indian company or LLP with FDI or ODI files it on RBI's FLAIR portal by 15 July. Who files, steps, ₹7,500 late fee and FAQs. CA-led filing.
The FLA return (Annual Return on Foreign Liabilities and Assets) is a yearly RBI filing that every Indian company, LLP or other resident entity with foreign direct investment (FDI) and/or overseas direct investment (ODI) outstanding at the end of March must submit by 15 July on the RBI's FLAIR portal. It may be filed on unaudited figures if the audit is not done by then, and a late return can be regularised with a ₹7,500 Late Submission Fee.
This guide covers who has to file, what goes into the return, the step-by-step process on FLAIR, the late fee, and how the FLA return differs from FC-GPR and the APR. The return for the year ended 31 March 2026 was due on 15 July 2026; the next one, for the year ending 31 March 2027, is due on 15 July 2027.
Who must file the FLA return
The RBI's FAQ is framed around one test: does the entity have outstanding FDI or ODI as on end-March of the reporting year or the previous year? If yes, it files. Because the return reports two years side by side, an entity that received FDI or made an overseas investment in either year is in, even if the investment has since been repaid or sold.
| Your position | File the FLA return? |
|---|---|
| Company with foreign shareholding (any percentage) at end-March | Yes |
| LLP that has received FDI | Yes |
| Indian entity with a foreign subsidiary, joint venture or other ODI | Yes |
| FDI received during the year only, still outstanding at end-March | Yes |
| FDI or ODI fully exited during the reporting year (outstanding at the previous end-March) | Yes, because the previous year column is non-zero |
| SEBI-registered AIF with foreign investment | Yes, through the email-based Excel form after registering on FLAIR |
| Partnership firm or other "Others" entity with foreign investment | Yes |
| Only share application money received, no allotment | No, per RBI FAQ |
| No outstanding FDI or ODI at end-March of the reporting year and the previous year | No |
There is no turnover or size threshold. A start-up with one foreign shareholder holding a single share files the same return as a listed multinational. The RBI uses the return to compile India's external sector statistics, so it is about the stock of foreign investment, not about whether money moved this year.
Due date, unaudited figures and revision
- Due date: 15 July of the reporting year, based on the entity's audited or unaudited financials for the year ended 31 March.
- Unaudited figures are allowed. If the audit is not complete, file on provisional or unaudited accounts by 15 July. Do not wait for the audit and miss the date.
- Revision after audit: once audited accounts are ready, request RBI permission on FLAIR to submit a revised return. The RBI FAQ says to revise after that approval irrespective of the size of the variation, and to do it as soon as the audited statements are available.
- There is no fixed revision deadline in the RBI FAQ. Some guides quote 30 September; that is not in the RBI's own FAQ.
What is reported in the FLA return
| Section | What goes in it |
|---|---|
| Section I | Identification: CIN / LLPIN / UIN, PAN, contact, type of shares, category of inward FDI (associate if one foreign investor holds 10% to 50%, subsidiary if above 50%), foreign technical collaboration |
| Section II | Financial particulars: paid-up capital, reserves and surplus, revenue, profit; all amounts in ₹ lakh |
| Section III | Inward investment: FDI (10% or more), other direct investment below 10%, portfolio and other liabilities to non-residents, for the previous and current end-March |
| Section IV | Outward investment: ODI (10% or more in an overseas entity), portfolio and other foreign assets, for both years |
| Section V | Validation, declaration and submission |
Three rules from the RBI FLAIR FAQ trip up first-time filers. Amounts are in ₹ lakh, so ₹1,50,000 is entered as 1.5. Domestic assets and liabilities, including those in foreign currency and EEFC balances, are excluded. And unlisted equity is reported at market value worked out on the own funds at book value method: net worth of the investee multiplied by the percentage held, where net worth is paid-up equity and participating preference capital plus reserves and surplus, less accumulated losses.
How to file the FLA return on FLAIR, step by step
- Register (first time, or after a change of authorised person, name, address or CIN/LLPIN). On flair.rbi.org.in, enter entity type, CIN/LLPIN/UIN, PAN, registered address and authorised person details, and upload the portal's Verification Letter (as a PDF, unaltered) and a signed Authority Letter. The PAN and CIN must match across the form and the letters, or registration fails.
- Log in and change the default password. The default password is valid for 24 hours; the login OTP for 5 minutes.
- Fill Sections I to IV from the financial statements for the reporting year and the previous year, using the FDI and ODI reporting already filed with your AD bank as the cross-check.
- Validate. Click validate and clear every error in the variation report. Large swings between the two years are flagged and need either a correction or an explanation.
- Declare and submit. Confirm the declaration and submit before 15 July.
- Download the PDF and the acknowledgement. If no acknowledgement appears, write to flareturn@rbi.org.in; a confirmation from that address counts as acknowledgement.
Documents to keep ready
- Financial statements for the reporting year (audited or provisional) and the previous year
- Shareholding pattern at both end-March dates, showing each non-resident investor and percentage held
- FC-GPR and FC-TRS acknowledgements, and the FIRMS entity master data
- For ODI: Form ODI acknowledgements, the latest financial statements of each overseas entity and the last APR filed
- Details of any external commercial borrowing, trade credit, or other liabilities to and claims on non-residents
- Board resolution or authority letter for the person filing, plus that person's PAN
- CIN / LLPIN, PAN and NIC-2025 industry code (the activity that generates most of the revenue)
Late submission fee and penalty
Missing 15 July is a contravention of FEMA. RBI A.P. (DIR Series) Circular No. 16 of 30 September 2022 introduced a Late Submission Fee (LSF) route to regularise reporting delays without compounding. For returns that do not capture flows, a group that expressly includes the FLA return, the LSF is a fixed ₹7,500 per return, however long the delay.
| Point | Position under the LSF circular |
|---|---|
| LSF for a delayed FLA return | ₹7,500 per return (fixed) |
| LSF for flow-capturing forms (FC-GPR, FC-TRS, ECB etc.) | ₹7,500 + 0.025% × amount × years of delay, capped at 100% of the amount |
| How long the LSF option is open | Up to three years from the due date |
| Fee advice not paid within 30 days | Treated as void; the payment is not accepted later |
| Delay beyond the LSF window, or LSF not paid | Exposed to penal action under FEMA, usually resolved by compounding |
The RBI FLA FAQ asks entities that have to pay an LSF to contact the Foreign Exchange Department of the RBI Regional Office. A worked example: an LLP that missed the July 2025 and July 2026 FLA returns has two delayed returns, so the LSF is 2 × ₹7,500 = ₹15,000, provided both are filed and the fee paid within three years of each due date.
FLA return vs FC-GPR vs APR
| Point | FLA return | FC-GPR | APR |
|---|---|---|---|
| What it reports | Stock of foreign liabilities and assets at end-March | Issue of shares or other capital instruments to a non-resident | Performance of each overseas entity in which an ODI is held |
| Who files | Indian entity with outstanding FDI and/or ODI | Indian company issuing the instruments | Indian entity or resident individual holding the ODI |
| When | Every year by 15 July | Within 30 days of the issue | Every year by 31 December, on the overseas entity's accounts |
| Where | FLAIR portal (RBI DSIM) | FIRMS portal, through the AD bank | Through the AD bank |
| Late fee (LSF) | ₹7,500 fixed | ₹7,500 + variable part | ₹7,500 fixed |
| Trigger | Annual, while investment is outstanding | Each allotment | Annual, while the ODI is held |
An APR is not required where the Indian person holds less than 10% of the overseas entity without control and has no financial commitment other than equity, or where the overseas entity is under liquidation (Regulation 10(4) of the FEM (Overseas Investment) Regulations, 2022). The FLA return is required under Regulation 10(5) of the same Regulations, and the RBI decides its timing.
Common mistakes we see
- Assuming no FLA return is due because no money came in this year. If FDI or ODI was outstanding at either end-March, it is due.
- Entering figures in rupees or crore instead of ₹ lakh, which throws every validation check.
- Reporting foreign investment at face value instead of market value under the book value method.
- Including domestic foreign currency loans or EEFC balances, which the RBI excludes.
- Waiting for the audit and missing 15 July, when provisional figures are allowed.
- Revising after the audit without first raising the revision request on FLAIR.
- Treating the FLA return as a substitute for the APR, or the reverse. They are separate filings with separate due dates.
- Letting the FLAIR registration lapse with a former director or CFO as the authorised person, so nobody can log in near the deadline.
How CorporateWalla helps
Our CA team reconciles your shareholding, FIRMS records and accounts before anything goes on FLAIR, files the return before 15 July, and handles the revision once the audit is signed. For a missed return, we file it and apply for the LSF within the window. FLA filing is part of our FEMA compliance service, from ₹8,999. If you are an NRI investing in an Indian company, our FEMA guide for NRIs explains the investor side, and NRI company registration covers setting up the Indian entity in the first place.
The FLA return is a statistical return to the RBI, not a tax filing. It does not replace your ROC annual filings or income tax return. See ROC vs RBI vs SEBI for which regulator handles what.
Frequently asked questions
Q: What is the FLA return?
A: The Annual Return on Foreign Liabilities and Assets is an RBI return in which Indian entities with foreign direct investment or overseas direct investment report their foreign liabilities and assets as at end-March of the current and previous year. It is filed online on the RBI's FLAIR portal and is used to compile India's external sector statistics.
Q: What is the due date for the FLA return?
A: 15 July every year, for the financial year ended on the preceding 31 March. The return for FY 2025-26 was due on 15 July 2026, and the return for FY 2026-27 is due on 15 July 2027. It can be filed on unaudited figures and revised after the audit with RBI permission.
Q: Who is required to file the FLA return?
A: Every Indian resident company, LLP, SEBI-registered AIF, partnership firm or other entity that has outstanding FDI and/or ODI as on end-March of the reporting year or the previous year. There is no size threshold. An entity with no outstanding FDI or ODI at both dates need not file.
Q: Do LLPs have to file the FLA return?
A: Yes. LLPs registered under the LLP Act, 2008 are expressly covered, and register on FLAIR with their LLPIN. An LLP with foreign contribution or an overseas investment at either end-March files exactly as a company would.
Q: Can I file the FLA return without audited accounts?
A: Yes. The RBI allows the FLA return to be filed by 15 July on provisional or unaudited financial statements. Once the audit is complete, raise a request on FLAIR for permission to submit a revised return and file the audited figures, whatever the size of the difference.
Q: What is the late fee for the FLA return?
A: Under RBI A.P. (DIR Series) Circular No. 16 dated 30 September 2022, a delayed FLA return can be regularised with a fixed Late Submission Fee of ₹7,500 per return, available up to three years from the due date. Beyond that, or if the fee is not paid, the delay is a FEMA contravention open to penal action.
Q: Is a nil FLA return required if there was no FDI this year?
A: Only if there was outstanding FDI or ODI at end-March of the previous year. Because the return covers two years, an investment outstanding at either date makes it due. If both end-March positions are nil, no return is needed and there is no nil-return requirement.
Q: Is the FLA return the same as the APR?
A: No. The APR reports the performance of each overseas entity in which an Indian person holds an ODI, filed through the AD bank by 31 December each year. The FLA return reports the entity's whole foreign asset and liability position to the RBI by 15 July. An Indian company with an overseas subsidiary usually files both.
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