File the FLA Return explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
To file the FLA return, register the entity on the RBI's FLAIR portal, enter foreign liabilities and assets as on 31 March (FDI received and overseas investment made), and submit online by 15 July under FEMA, 1999. If accounts are unaudited by then, file provisional figures and revise by September.
Overview
The Foreign Liabilities and Assets (FLA) return is an annual filing with the Reserve Bank of India that captures a company's cross-border investment position — foreign direct investment received and overseas direct investment made. It is a FEMA compliance, separate from any MCA filing.
When It Is Required & Legal Basis
The FLA return is mandated under the Foreign Exchange Management Act, 1999. Every Indian company, LLP or other entity that has FDI (foreign liabilities) or overseas direct investment (foreign assets), either during the reporting year or outstanding from earlier years, must file it on the RBI FLAIR portal.
Step-by-Step Process
- Register on FLAIR. Create a user login on the RBI FLAIR portal using the entity's authorised person details.
- Gather data. Compile share capital, reserves, foreign shareholding, overseas investments and related figures as on 31 March.
- Determine audited vs provisional. Use audited figures if available; otherwise use provisional numbers.
- Fill the online form. Enter balance-sheet and foreign-investment data into the FLAIR return sections.
- Submit by 15 July. Validate and submit the return; download the acknowledgment.
- Revise if provisional. If provisional figures were used, submit a revised return with audited numbers by end September.
Forms, Attachments & Fees
| Item | Purpose | Timeline |
|---|---|---|
| FLAIR registration | Create entity login on RBI portal | Before first filing |
| FLA return | Report foreign liabilities and assets | By 15 July |
| Revised FLA return | Update provisional to audited figures | By end September |
There is no filing fee for the FLA return; it is submitted directly on the RBI FLAIR portal.
Timeline & Due Dates
The FLA return reports the position as on 31 March and is due by 15 July each year. Where audited accounts are not finalised, a provisional return by 15 July followed by a revised audited return by end September is accepted.
Penalty for Delay / Non-compliance
Non-filing or delayed filing of the FLA return is a contravention of FEMA, 1999. Under Section 13 of FEMA, it can attract a penalty up to thrice the sum involved where quantifiable, or up to ₹2,00,000 where not quantifiable, with a further ₹5,000 per day for continuing contravention. Such contraventions may also be compounded through the RBI compounding process.
Practical Tips
- Do not confuse FLA with MCA filings — it is filed with the RBI, and both must be done.
- Even a company with only outstanding (not fresh) FDI must file every year until the foreign investment is fully exited.
- Keep the FLAIR acknowledgment on file; it is often sought during FDI-related certifications.