Filing of FLA Return Made Easy

Avoid Penalties, Stay Compliant

What is FLA Return

The Foreign Liabilities and Assets (FLA) Return is a mandatory annual filing required by the Reserve Bank of India (RBI) from Indian entities that have received Foreign Direct Investment (FDI) or made Overseas Direct Investment (ODI) in any of the previous or current financial years. The return is filed under the provisions of the Foreign Exchange Management Act (FEMA), 1999, and helps the RBI compile data on India’s foreign assets and liabilities.

FLA Return is submitted electronically through the FLAIR Portal (Foreign Liabilities and Assets Information Reporting System), and non-compliance can attract penal consequences under FEMA.

Applicability of FLA Return

FLA Return is required to be filed by the following categories of entities:

  • All Indian companies that have received FDI and/or made ODI during any financial year.

  • Indian companies that hold foreign assets or liabilities in the form of shares, loans, trade credits, etc.

  • Limited Liability Partnerships (LLPs) and Alternative Investment Funds (AIFs) that have received capital or made investments from/to outside India under FEMA provisions.

  • Companies that have not received FDI in the current year, but had FDI in earlier years and the investment is still outstanding in the balance sheet.

Entities not having any outstanding FDI/ODI as of March 31 of the reporting year are not required to file.

Purpose and Objective

The main purpose of the FLA Return is to:

  • Track foreign investments into and from India.

  • Enable the Reserve Bank of India to maintain updated and comprehensive statistics on international investment positions (IIP).

  • Facilitate effective policymaking on capital inflows, outflows, and cross-border economic activities.

 

This information also helps RBI comply with data-sharing obligations under IMF’s Special Data Dissemination Standard (SDDS).

Due Date and Filing Timeline

  • Reporting Date: Data as on 31st March of the financial year.

  • Due Date for Filing: 15th July of the following financial year.

  • Revised Filing: In case the return is filed based on provisional data, the entity may revise the return once final audited financial statements are available.

Late filing or non-filing of the return constitutes a contravention under FEMA and can attract penalties.

Data and Documents Required

Entities must prepare the following information in order to file the FLA Return:

1. General Information

  • Name of the company/LLP

  • PAN and CIN

  • Email ID and contact details

  • Sector classification (as per NIC codes)

2. Financial Information

  • Total Paid-up Capital

  • Reserves and Surplus

  • Profit & Loss details (for the current year)

3. Foreign Liabilities

  • Details of FDI received: country-wise and investor-wise

  • Type of instrument (equity, CCDs, preference shares, etc.)

  • Outstanding amount of foreign liabilities as on 31st March

  • Trade credits or external commercial borrowings (ECBs)

4. Foreign Assets

  • Investment made in subsidiaries, associates, or branches outside India

  • Country-wise break-up

  • Nature of holding (equity/debt)

Step-by-Step Process for Filing

1. Registration on FLAIR Portal

Entities that are filing for the first time must register on the FLAIR portal at https://flair.rbi.org.in. Existing users can log in using their credentials.

2. Preparation of Data

Prepare data on foreign liabilities and assets based on provisional or audited financials as of 31st March.

3. Validation and Submission

Fill in all required fields, validate the form, and submit the return online. A system-generated acknowledgment is issued after successful filing.

4. Revision (if needed)

Entities may revise the return if audited financials differ significantly from provisional data.

Consequences of Non-Compliance

FLA Return is governed under FEMA, and failure to comply may result in the following:

  • Contravention proceedings under Section 13 of FEMA, 1999

  • Levy of compounding penalties, which may include monetary fines

  • Ineligibility to receive future foreign investment approvals from RBI

Common Errors to Avoid

  • Filing with incorrect CIN or entity details

  • Mismatch between shareholding pattern and investment reported

  • Ignoring dormant or non-operating FDI companies with outstanding investments

  • Not updating the RBI about changes in contact details or authorized personnel

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