Annual Return on Foreign Liabilities and Assets (FLA): Who Must File and Key Compliance Requirements

The Annual Return on Foreign Liabilities and Assets (FLA Return) is an important annual reporting requirement prescribed by the Reserve Bank of India (RBI). Entities with foreign investment or overseas investment must ensure timely filing to remain compliant with the provisions of the Foreign Exchange Management Act, 1999 (FEMA).

What is the FLA Return?

The FLA Return is an annual statistical return that captures details of foreign liabilities (such as Foreign Direct Investment - FDI) and foreign assets (such as Overseas Direct Investment - ODI) held by Indian resident entities as on 31st March of the relevant financial year.

The return is mandatory under FEMA, 1999 and was introduced through RBI A.P. (DIR Series) Circular No. 45 dated 15 March 2011. It is now filed online through the RBI's Foreign Liabilities and Assets Information Reporting (FLAIR) Portal. (TaxGuru)

Who is Required to File?

As per the latest RBI FAQs (updated on 1 July 2026), the following Indian resident entities are required to file the FLA Return if they have outstanding Foreign Direct Investment (FDI) and/or Overseas Direct Investment (ODI) as on the end of March of the reporting year:

• Companies

• Limited Liability Partnerships (LLPs)

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• SEBI-registered Alternative Investment Funds (AIFs)

• Partnership Firms

• Public Private Partnerships (PPPs)

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• Other eligible resident entities having outstanding foreign assets or liabilities

The filing requirement applies even if the foreign investment was received or made in any previous year and continues to remain outstanding as on 31 March. (TaxGuru)

Due Date for Filing

The Annual FLA Return must be filed on or before 15 July every year through the RBI's FLAIR portal.

If the audited financial statements are not available by the due date, the return should be filed using provisional or unaudited financial statements. Once the accounts are audited, a revised return may be submitted with RBI approval, wherever applicable. (TaxGuru)

When is Filing Not Required?

Generally, an entity is not required to file the FLA Return if:

• It does not have any outstanding inward FDI or outward ODI as on 31 March of the reporting year.

• Foreign investment has been completely extinguished before the reporting date and no foreign assets or liabilities remain outstanding. (TaxGuru)

Consequences of Non-Compliance

Failure to submit the FLA Return is treated as a contravention under FEMA, 1999. Such non-compliance may attract regulatory action, including penalties and compounding proceedings, depending on the facts of the case. Timely filing helps avoid unnecessary compliance issues with the RBI. (TaxGuru)

Practical Tips for Businesses

• Review foreign shareholding and overseas investments before the due date.

• Keep financial statements and investment records ready.

• Verify whether any outstanding foreign investment exists as on 31 March.

• File the return through the RBI FLAIR portal well before the deadline.

• Where audited accounts are pending, submit the return based on provisional figures and revise it later if required.

Conclusion

The Annual FLA Return is a key FEMA compliance for Indian entities with foreign investment or overseas investments. Businesses should assess their reporting obligation each year and ensure accurate and timely filing through the RBI's FLAIR portal to avoid regulatory consequences.

For expert guidance on this topic, contact your tax professional today.

EXCERPT: Companies and other resident entities with outstanding FDI or ODI must file the Annual FLA Return with RBI by 15 July. Ensure timely FEMA compliance.

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