FLA Return Filing Online with RBI (FEMA Compliance)
If your Indian entity is making the foreign investment, then file the Foreign Liabilities and Assets (FLA) return with the Reserve Bank of India (RBI) by the last date of 15th July. You can file a revised return on September 30 of the same year to update your return with final audited financial statements. JustStart FEMA Experts can seamlessly manage this compliance and file your return quickly.
- 15 July/ Every Year
- RBI FLAIR Portal
- 30 September Revised FLA
- Late Filing ₹7,500/ Per Return
- FEMA Compliance Alignment
Everything Included in Your FLA Return Filing Package:
- Online Filing Via RBI’s FLAIR Portal
- Check FLA Return Applicability
- Complete RBI Guidance to ODI & FDI Entities
- Manage Foreign Investment Records
- Due Date & Penalty Tracking
- Verify Registration & Financial Record Documents
Request a Callback
4.9 star all time rating
4.8 star all time rating
Overview
What is FLA Return Filing?
The Foreign Liabilities and Assets (FLA) return filing is a compulsory compliance formality under the FEMA, 1999 for Indian enterprises and companies. Whether you are making Foreign Direct Investment (FDI) by receiving foreign investment or Overseas Direct Investment (ODI), filing the FLA return is crucial. Meanwhile, an FLA return is filed as long as outstanding foreign investments exist on the balance sheet date, regardless of transaction activity during the year.
The primary approaches for filing the FLA return are set out under the Foreign Exchange Management Act (FEMA), 1999, both in terms of the nature of the FLA return and the procedure for filing with the RBI, as named by the Department of Statistics and Information Management of the RBI. On the other hand, the RBI's FLAIR portal is marked as the primary return filing system. However, if an Indian entity fails to file or delays filing the FLA return, it triggers a possible penalty/compounding under Section 13 of FEMA, 1999.
Eligibility
What is the FLA Return Applicability?
FLA Return filing online in India is mandatory unless you have zero outstanding liabilities or foreign assets on your balance sheet. To file the RBI FLA return online, the applicant Indian entity is required to meet the specific guidelines. Meanwhile, these are the major entities that must file the return on or before its due date:
Who Must File?
- Companies: All companies registered under the Companies Act, 2013, such as Private Limited, Public Limited, or OPCs that have received FDI or made ODI.
- Limited Liability Partnership (LLP): Filing is applicable to all LLPs that have made foreign investment or made overseas investment.
- Alternative Investment Funds (AIFs): Applicable to all SEBI-registered AIFs that have foreign liabilities or assets.
- Partnership Firms: Partnership firms are also applicable if they make inward or outward investments.
- Public-Private Partnership (PPPs): Any PPP entity that holds foreign investment.
Who is Exempt from Filing?
- No Foreign Investment: Filing the Foreign Liabilities and Assets (FLA) return is not obligatory if no Indian entity has accepted FDI or made an ODI.
- Shares Pending Allotment: You are not required to file if your entity has only received share application money, but the shares are pending allotment.
- Non-Repatriable Investment: If your entity received investment strictly on a non-repatriable basis from Non-Resident Indians (NRIs).
Important Compliance Callout: If you have not earned any new foreign investment or made any foreign direct investment during the last year in India, you are still obliged by law to submit the FLA form. This is because the filing process is based on your previously reported foreign liabilities or assets. It means that if your balance sheet shows some foreign liabilities or assets as at 31 March, the filing becomes legally required.
Due Dates
FLA Return Due Date & Revised Return
Under the provisions of the RBI and FEMA framework, the standard FLA return due date for submitting the Foreign Liabilities and Assets (FLA) return is 15 July every year for the previous financial year ending March 31. The form is submitted on RBI’s FLAIR portal online. The FLA return due date is as follows:
|
|
|
|
|
|
|
|
|
|
|
|
Note: In FY 2023-24, FY 2024-25 and FY 2025-26, the RBI extended the due date from 15 July to 31 July.
Documents Required
What Documents Are Required for FLA Return Filing?
Before proceeding with the return submission process, the Indian company must ensure that it has collected all required information. Must prepare all these documents before starting the filing process:
- Letter of Authority: The designated user must sign and scan this document.
- Consequential Letter/Confirmation: This document must be in PDF format to establish the entity’s details along with the PAN/CIN of the authorized person.
- Entity’s PAN and CIN: In order to confirm the identity of the entity, the Certificate of Incorporation/LLPIN of the entity will be needed.
- Authorized Person PAN: The authorized person must submit his/her PAN.
- Financial Statements: The required financial accounts must be either audited or provisional/unaudited up to March 31.
- Foreign Direct Investment (FDI): This will include information related to inward foreign investment as well as the non-resident shareholding percentage.
- Overseas Direct Investment (ODI): This will include information about financial commitment and joint venture/subsidiary abroad.
- Operational Information: Operation-related information consists of information related to sales and purchases.
- Other Capital/Debt: This includes internal loans, trade credits, and external commercial borrowing.
Procedure
Complete Process of FLA Return Online in India
FLA return is filed online on the FLAIR portal, and the Indian entity is further mandated to attach the papers to it. Follow this RBI FLA return online process:
Step 1: Login FLAIR Portal
Visit the RBI's FLAIR portal and navigate to the user registration credentials. On the letterhead, attach the scanned Authority letter along with the verification letter.
Step 2: Get Your Login Credentials
Once the entity documents are verified by the RBI, you will receive your official system-generated login credentials at your registered email address.
Step 3: Log in & Select Reporting Year
Log in to the portal using your username and password. To register your mobile number, complete the two-factor authentication by entering the OTP. Click on the FLA return application to select the current financial year.
Step 4: Fill Part I: Entity Details
Under this section, you are required to fill in the financial and identification data. In detail, you are required to mention your entity parameters like CIN/LLPIN, entity’s PAN, total paid-up capital, and operational sales/purchase figures.
Step 5: Fill Part II: FDI Details
In this section, you are required to mention the details of Foreign Direct Investment (FDI) such as non-resident equity shareholding, Compulsorily Convertible Preference Shares (CCPS), Compulsorily Convertible Debentures (CCDs), and outstanding non-resident liabilities.
Step 6: Fill Part III: ODI Details
Under this section, you must mention the outward investment details. The major information you are required to mention includes financial commitments, equity holdings, loan balance, and the value of foreign assets in overseas Joint Ventures (JVs).
Step 7: Review Part IV/V: Auto-Generated Statements
On the system-computed, review the net liability/ assets positions and verify the variation section.
Step 8: Validate & Submit Return
Navigate the online validation sections and verify that no details are left. Upon successful verification and error-free submission, submit the FLA Return on the RBI FLAIR portal.
Step 9: Download Disclosure
Save and download the system-generated online acknowledgement receipt. You can use it for compliance purposes.
Format
FLA Return Format: What Each Part Captures
The FLA return format is categorized into five core parts/ section. Each section contains unique informational details of the entity and the individual. The FLA return format is structured as:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Penalties
Penalties for Late or Non-Filing of FLA Return
Indian entities face strict legal and statutory action under FEMA 1999 if they fail to file or delay filing the FLA return. These are the major penalties you might face due to FLA return non-compliance:
Late Submission Fee (LSF)
The indian entity will be charged ₹7,500 per return if delayed in filing the FLA return for up to 3 consecutive years from the due date.
Non-Quantifiable Penalty
Under FEMA Section 13, the Indian entity will be charged ₹ 2,00,000 if the violation sum cannot be quantified.
Quantifiable Penalty
Up to 300% (3x the total sum) of the amount involved in serious or hidden foreign investment breaches.
Default-Continue
If the default is continued, the offender entity faces a fine penalty of up to ₹5,000 per additional day, or a daily compounding fine enforced for ongoing non-compliance after detection.
Non-Financial Consequences
Non-compliance triggers a blockage by the AD (Authorised Dealer) authority, resulting in blockage of complete inward/outward remittances, restrictions on future filings or being flagged as non-compliant on the RBI database.
Why Choose JustStart?
Why File Your FLA Return with JustStart?
Filing the FLA return online is complex for Indian entities that are not very aware of the FEMA regulations, balance sheet metrics, and RBI FLAIR portal technicalities. But no need to worry, as JustStart provides direct, expert-driven support to file the FLA return before its due date.
Timeline Commitment
To avoid due date delays, our experienced professionals prepare and submit the documents within a short timeframe.
Data Verification by CS/CA
Prior to portal filing, our dedicated Chartered Accountants and Company Secretaries verify all required data to avoid rejection.
100% Error-Free FLAIR Submission
Our dedicated professionals accurately report across all five sections. This helps to ensure that your entity’s net liabilities and assets align precisely with statutory financial statements.
Fixed-Transparent Price
Fixed professional fees with no hidden charges. Your FLA return will be filed at a fixed price with 100% pure, authentic support.
Locations
FLA Return Filing in Other States and Cities
FAQs
LET'S CLEAR ALL THE DOUBTS!
The Foreign Liabilities and Assets Return is a mandatory annual reporting form that is submitted by Indian entities to the RBI (Reserve Bank of India). However, it is only applicable when the Indian entity has received or made foreign investment.
Filing the FLA return is mandatory for Indian resident entities that received Foreign Direct Investment (FDI) or made Overseas Direct Investment (ODI) abroad in the current or previous financial year.
The standard FLA return due date for submitting the foreign investment annual return on the RBI FLAIR portal is 15 July every year.
Yes, FLA return applicability also covers LLPs, but only when they receive or make foreign investment. However, LLPs with zero outstanding inward investment or outstanding investment are not required to file the FLA return.
Failure to file the Foreign Liabilities and Assets (FLA) return before the due date triggers possible legal and financial penalties under the FEMA, 1999. The flat late fee is ₹7,500 for delaying the filing.
Yes, you can file the revised FLA return upon successful completion of your audited financial statements. The due date for the revised FLA return is 30 September of the same year.
Submitting the FLA return on RBI’s FLAIR portal is mandatory, and annual compliance is required as it helps to track India’s cross-border capital flow; RBI gets access to monitor the foreign debt and equity exposure.
FLA return is an annual reporting of total outstanding foreign liabilities and assets, whereas FC-GPR is a transaction-specific filing triggered only when capital assets are allotted to non-resident investors.
No, there is no government or statutory filing fee to submit the FLA return to the RBI on the FLAIR portal online. Even the revised FLA return fee is zero.
The professional fees for the FLA return range from ₹4,999 to ₹24,999+, depending on the specific service scope.
