Annual Compliance for Foreign Assets

FLA Return
Filing

Mandatory annual filing for Indian companies and LLPs having foreign assets or liabilities (FDI/ODI). Ensure compliance with RBI regulations and avoid massive penalties.

Satisfied NSDC Partner Verified Training Centre Registered Training Provider
+35k

Trusted by 35,000+ Businesses

Step 1/3

Start FLA Return Filing

Fill in the form and complete process to receive your certificate.

100% Secure & Confidential

Note: We are India's fastest growing online business services platform dedicated to helping people to start and grow their business, at an affordable cost. Our aim is to help the entrepreneur with regulatory requirements, and offering support at every stage to ensure the business remains compliant and continually growing. We are Private Organization and providing services and assistance for Business Benefits who require consultation.

Annual Return by RBI

What is FLA Return?

FLA Return is an annual filing mandated by the Reserve Bank of India under FEMA for Indian companies and LLPs holding foreign assets or liabilities. It helps RBI track cross-border investments. Entities receiving FDI, making ODI, or holding foreign loans must file it by 15th July for the previous financial year. Non-compliance attracts FEMA penalties.

FLA Overview

Definition and Purpose

The FLA Return (Foreign Liabilities and Assets Return) is an annual mandatory filing required by the Reserve Bank of India (RBI) under the Foreign Exchange Management Act (FEMA), 1999. It is designed to collect information on the foreign assets and liabilities held by Indian companies, LLPs, and other entities that have received Foreign Direct Investment (FDI) or made Overseas Direct Investment (ODI). This return provides the RBI with essential data to monitor cross-border capital flows, helping formulate macroeconomic policies and maintain balance-of-payment statistics.

Reporting Basis

Entities must submit the return each year by 15th July, reflecting their foreign financial position as of 31st March of the relevant financial year.

FLAIR Portal

Filing is done online on the RBI’s FLAIR portal (Foreign Liabilities and Assets Information Reporting System).

Applicability

Who Needs to File FLA Return?

Indian entities with direct or indirect foreign investments are legally obligated to submit FLA returns.

1

Companies/LLPs that have received FDI

All Indian companies and LLPs that have received FDI (Foreign Direct Investment) during the financial year or in earlier years and still hold FDI as of 31st March.

2

Companies that have made ODI or hold foreign assets

Companies that have made ODI (Overseas Direct Investment) or hold foreign assets, such as subsidiaries, joint ventures, or branches abroad.

3

Entities with ECBs or foreign loans

Entities that have outstanding external commercial borrowings (ECBs) or foreign loans.

4

No transactions, but assets/liabilities exist

Even if there are no transactions during the year, but foreign liabilities or assets exist, filing is mandatory.

This requirement ensures that the RBI can maintain an accurate record of India’s international investment position, making it crucial for businesses with global exposure to stay compliant.

Benefits

Importance of FLA Filing

Filing the FLA Return ensures legal transparency and operational continuity for Indian entities engaged in international finance.

1

Regulatory Compliance with RBI Guidelines

FLA Return is a mandatory annual submission under Foreign Exchange Management Act (FEMA), governed by the Reserve Bank of India (RBI). Filing ensures your company is in full compliance with Indian exchange control laws, helping avoid any regulatory red flags.

2

Avoiding Penalties and Legal Scrutiny

Failure to file the FLA Return within the stipulated deadline (usually 15th July) can lead to severe consequences, including monetary penalties under FEMA, reputational damage, and increased scrutiny from regulators. Timely filing protects your business from such risks.

3

Transparency in Foreign Investments Liabilities

The return serves as a key mechanism for the RBI to assess India’s foreign asset position. By filing the FLA, companies contribute to the country's official data on foreign direct investment (FDI), overseas direct investment (ODI), and other cross-border financial flows—ensuring transparency and accurate representation.

4

Requirement for Indian Entities with FDI or Overseas Assets

Any Indian company or LLP that has received foreign investment, made investments abroad, or holds external commercial borrowings (ECBs) must file the FLA Return. It's a compliance checkpoint to declare such financial relationships in a legal and structured manner.

Eligibility

Who Needs to File?

The Foreign Liabilities and Assets (FLA) Return must be filed annually by Indian entities engaged in foreign transactions or holding cross-border investments. The Reserve Bank of India (RBI) mandates this return under FEMA regulations to track India’s external financial assets and liabilities.

Companies Receiving Foreign Direct Investment (FDI)

All Indian companies that have received FDI—even once—must file the FLA Return. Example: A private limited company that received equity capital from a foreign investor is required to comply.

Companies Making Overseas Direct Investments (ODI)

If an Indian company has invested abroad—JV, WOS, or stake in a foreign company—it must file the return, even if no returns have been generated yet.

LLPs with Foreign Investment

LLPs with foreign capital contributions or foreign assets/liabilities must submit the FLA Return. This includes LLPs having non-resident partners.

Companies with External Commercial Borrowings (ECBs)

Indian entities borrowing via ECB—banks, institutions, or foreign shareholders—fall within the FLA filing requirement.

Companies with Outstanding Foreign Liabilities or Assets

Companies with outstanding foreign liabilities or assets as of March 31st must file the FLA Return, even if no foreign transaction occurred during the year.

Dormant Companies & Exempt Entities

Dormant or non-operational companies that still hold foreign assets or liabilities must file the return. Only entities having zero foreign assets, zero foreign liabilities, no FDI, and no ODI are exempt. If past foreign transactions exist on the balance sheet, filing remains mandatory.

Entities Exempt from Filing

Companies or LLPs having no foreign liabilities, no foreign assets, no FDI, and no ODI are exempt from filing the FLA Return. However, if past foreign transactions exist on the balance sheet, filing remains mandatory.

Checklist

Required Documents

Accuracy in submission depends on having these essential financial and entity-related documents ready.

Audited Financial Statements (as on 31st March)

Audited Balance Sheet and Profit & Loss Statement of the relevant financial year to extract figures on foreign assets/liabilities and reserves.

Provisional Financials (if audit is pending)

If audited financials are not available before 15th July, provisional statements may be used. However, audited financials must be filed once available.

FIRC (Foreign Inward Remittance Certificate)

Required to verify receipt of foreign capital in India and confirm the nature/amount of investment received.

Shareholding Pattern / Cap Table

Structure showing Indian and foreign shareholders, holdings and ownership percentage for calculating direct/indirect foreign investment.

ODI/FDI Reporting Documents (if applicable)

Copies of Form ODI, Form FC-GPR, Form FC-TRS and other RBI filings for reference while preparing the return.

Details of External Commercial Borrowings (ECBs)

Loan agreements, disbursement schedules, and outstanding balances as of 31st March if ECBs are raised.

FLA User Login Credentials

Authorized login credentials for the RBI’s FLAIR portal must be kept ready and secured.

Previous Year’s FLA Acknowledgement (if applicable)

Helpful for cross-verifying year-on-year changes and ensuring consistency in reporting.

Critical Timelines

Due Date and Penalties

Accurate and timely filing of the FLA Return is crucial for all eligible Indian entities. The Reserve Bank of India (RBI) enforces strict deadlines and compliance rules to ensure transparency in foreign investments. Non-compliance may result in penalties and complications in future reporting.

FLA Return Filing Due Date

Annual Due Date

15th July

Every Year

The due date for FLA Return is 15th July of every year. Entities must report foreign assets and liabilities as on 31st March of the previous financial year, regardless of whether the accounts are audited or provisional.

Timely filing via the RBI's FLAIR portal is mandatory to remain compliant.

Penalties for Non-Filing

Failure to file or delay in submitting the FLA Return is treated as a violation of the Foreign Exchange Management Act (FEMA), 1999. RBI may impose penalties, which can include:

₹10,000 for each violation (non-filing or delayed filing)

Further penalties up to ₹2,000 per day during the period of default

In severe cases, compounding applications may be required to regularize the non-compliance

Warning: Non-compliance can lead to serious legal and financial consequences. Always ensure timely filing.

Can FLA Return be Revised?

Yes, Revision is Allowed

Yes, the FLA Return can be revised after submission, provided the changes are justified and consistent with audited financials. Entities that initially file with provisional data must revise the return once audited financials become available.

Important Note

The FLAIR portal allows such revisions, but timely updates are critical to avoid regulatory scrutiny. Always maintain documentation supporting the revision.

Pro Tip for Compliance

Mark your calendar for 15th July every year and start preparing your FLA Return by early June. If audited financials are not ready, file with provisional data and revise later to avoid penalties. Keep all supporting documents organized for smooth filing and potential revisions.

Step-By-Step

Registration Process for FLA Return Filing

A simple and structured process to ensure compliant filing with the RBI.

1

Collect Financial and Foreign Transaction Details

Gather accurate financial data as of 31st March, including FDI, ODI, shareholding patterns, and any foreign liabilities or assets. Use provisional or audited data depending on availability.

2

Prepare FLA Form in Excel Utility

Download the official FLA Return Excel utility from the RBI website. Fill in the required fields such as general company details, investment information, liabilities, and assets related to foreign entities. Ensure all entries follow RBI-specified formats and codes.

3

Validate and Convert XML File

Use the inbuilt validation tool in the Excel utility to check for errors. Once the form is successfully validated, generate the XML file directly from the utility. This file format is required for uploading to the RBI FLAIR portal.

4

Upload on RBI FLAIR Portal

Login to the FLAIR portal using your Entity Identification Number (EIN). Upload the validated XML file and confirm the details match your financial records.

Confirmation and Filing Acknowledgement

Once uploaded, you’ll receive an acknowledgement email from RBI, confirming successful filing. This should be saved for audit and compliance records. If provisional data was used, ensure you revise the return later with audited figures.

Precautions

Common Mistakes to Avoid

Avoiding these common errors is crucial for accurate submission and regulatory adherence under RBI norms.

Incorrect Classification of Foreign Investment

Misreporting FDI as ODI (or vice versa) or improper classification of equity, debt, or retained earnings can trigger scrutiny due to discrepancies in RBI records.

Missing Registration on Entity Master Form

Entities not registered on RBI’s Entity Master Form (EMF) portal cannot file the FLA Return. Registration is a mandatory prerequisite for FLAIR portal access.

Using Unaudited Data Without Proper Declaration

Provisional figures may be used if audited financials are unavailable by 15th July—but they must be declared clearly and revised later with audited data.

Not Keeping Proper Records of FDI/OFDI Transactions

Inadequate documentation of transactions, remittances, or equity inflows/outflows leads to reporting errors and can hinder future RBI compliance or audits.

How We Help

How Udyog Suvidha Kendra Helps with FLA Return Filing

Udyog Suvidha Kendra offers end-to-end support to simplify the annual compliance process for businesses with foreign exposure.

1

Expert Compliance Support and Advisory

Our RBI compliance experts guide you through eligibility, documentation, and classification of FDI/OFDI, ensuring accuracy and adherence to legal provisions.

2

Preparation and Validation of FLA Return

We help compile data, fill the RBI Excel utility, validate entries, and generate the XML file ready for upload to the RBI FLAIR portal.

3

On-time Filing and Acknowledgement Assistance

From registration to final filing, we ensure timely submission and provide acknowledgement support, so you meet RBI deadlines without stress.

Support

Frequently Asked Questions

Find answers to common queries about RBI's FLA returns, FEMA penalties, and filing procedures.