Summary: Article provides a FAQ-based overview of the RBI’s Foreign Liabilities and Assets (FLA) Return requirements. It identifies entities required to file, including companies, LLPs, SEBI-registered Alternative Investment Funds, partnership and proprietary firms, and public-private partnerships that have received Foreign Direct Investment (FDI) or made Overseas Direct Investment (ODI). It states that the return covers the current and previous reporting years and that, for the financial year 2026, the due date has been extended from 15 July to 31 July as per a recent RBI notification. The update outlines late submission fees of ₹7,500, filing through the RBI’s FLAIR portal, registration and authorised person procedures, filing based on provisional financial statements with later revision after audit, and circumstances in which filing is or is not required, including share application money, non-repatriable investments, and investments involving IFSC entities regulated by IFSCA. It also notes that previous years’ returns and modifications require RBI approval, information is reported only for the April–March financial year, and no balance sheet or profit and loss account is required to be attached with the FLA Return.
Q1. Which entity needs to submit FLAReturn?
Ans. The following entities have received Foreign Direct Investment (FDI) or Overseas Direct Investment.
1. Companies formed under the Companies Act 2013.
2. Limited Liability Partnership (LLP)
3. SEBI-registered Alternative Investment Funds, Partnership and Proprietary Firms, Public Private Partnerships.
Q2. Reporting for which year?
Ans. Transaction occurred in the current year or Previous Year(s)
Q3. Due Date?
Ans. Every year 15th July, but as per recent RBI Notification, 31 July for this financial year 2026,
Q4. Consequences in case the said FLA return is not filed?
Ans. Payment of Late submission fees of 7500 Rs.
Q5. What portal deals with the submission of FLA Return?
Ans. The online web-based portal Foreign Liabilities and Assets Information Reporting (FLAIR) system by the RBI.
Q6. Process for new entity registration before filing FLA Return?
1. The entity has to register on the portal by clicking Registration for New Entity Users.
2. Fill the details in the FLA user registration form, upload the documents mentioned (Verification Letter and Authority Letter), and submit
3. User ID and default password will be sent to the authorized person’s email ID
4. Login FLAIR portal and file the FLA Return
Q7. Can an AIF file FLA Return Online through FLAIRportal?
Ans: There is no provision for online filing of FLA return for AIF; they need to send an email to flareturn@rbi.org.in. Below are the steps for filing the return in this case.
1. Register a new entity registration
2. Requesting via email for the latest format for filing of FLA Return for AIF.
3. FLA Team will send the Excel-based format for filing the FLA return only through email.
4. Email-based acknowledgement will be sent to them by the FLA team upon receiving and validating the filled-in FLA form.
Q8. When does an entity need to fill the registration form?
1. If the entity is filing the FLA Returns for the first time.
2. If the details of the authorized person have changed during the latest financial year.
3. If the Entity name/address has changed during the latest financial year.
4. If CorporateIdentification Number (CIN) / LLP Identification Number (LLPIN) / Others (UIN) / Partnership Firm – as on the latest financial year ending March has changed from that of the previous year.
Q9. Who is an authorized person?
1. The person who is authorized by the entity to fill and manage FLA Returns is called an Authorized person.
2. The Entity needs to furnish the details of its authorized person in the authority letter available on the FLAIR portal.
3. The default password and OTP (every time, whenever the company logs in to the FLAIR portal) are sent to the email of the authorized person furnished during registration.
Q10. What is the procedure to change the details of Authorized Person for FLA return submission?
Ans: The entity needs to send a request mail to RBI (flareturn@rbi.org.in) for deactivating the user, mentioning the entity Name, User Name, and entity CIN/LLPIN/UIN in the mail. FLA support team will take necessary action regarding this. Once the account is deactivated, you can re-register as a new user.
Q11. If the accounts/financials are not audited, is it possible to file FLA return with unaudited figures?
Ans. Yes, file the FLA return based on the available provisional/unaudited financial statements within the due date.
Once the audited financial accounts are ready, the entity is required to raise a request for submission of an updated FLA return through the FLAIR portal; upon approval, file the revised FLA return.
Q12. Entity needs to submit the FLA Return, if it has received only share application money?
Ans. No, the entity is not required to submit the FLA return unless allotted shares.
Q13. If the Indian entity has no outstanding FDI and/or ODI at the end of March of the current year. Is the FLA return still applicable for filing for the current year?
Ans. Yes, as the FLA return captures two years’ data (current year as well as previous year), if the entity has any outstanding foreign direct investment and/or overseas direct investment as on end-March of the reporting year and/ or previous year, then the entity is required to file the FLA return
Q14. If non-resident shareholders of an entity have transferred their shares to the residents during the reporting period, then whether that entity is required to submit the FLA Return.
Ans. If all non-resident shareholders have transferred their shares to the residents during the reporting period, then the entity may file the FLA return for the reporting period with details. the entity does not have any outstanding investment in respect of inward and/or outward FDI as on end-March of the reporting year for both the previous and current year, then the entity need not submit the FLA return.
Q15. If the resident shareholder of an entity becomes a non-resident because of shifting to a foreign country, should we report FLA?
Ans. In case all shares are issued on a non-repatriation basis only, then FLA need not be filed.
Q16. If an entity had issued the shares to non-residents on a non-repatriable basis, is that entity required to submit the FLA Return?
Ans. No, it’s not considered foreign investment; therefore, such companies are not required to submit the FLA Return.
Q17. Whether an entity regulated by International Financial Services Centre Authority (IFSCA) is required to file the FLA return for the financial year if it has received investment from outside India or holds investment outside India?
Ans: Yes. Such entities are advised to follow the relevant instructions issued by IFSCA for submission of FLA return. These entities are not required to file the FLA return with the RBI.
Q18. If a foreign entity establishes a subsidiary in IFSC, will that investment be classified as foreign direct investment, and will FLA filing apply to the subsidiary?
Ans: Yes, investment in a subsidiary in IFSC will be classified as inward foreign direct investment for the compilation of balance of payment and other external sector statistics. Submission of FLA return by such subsidiary will be required, and such entities are advised to follow the relevant instructions issued by IFSCA for submission of FLA return. These entities are not required to file the FLA return with RBI.
Q19. An Indian entity (entity A) has invested in an entity (entity B) which is regulated by IFSCA. Is this transaction treated as foreign investment for entity B? Is such equity investment in the form of ODI required to be reported in the FLA by entity A?
Ans: a) Entity A (Indian entity): Since Entity B is located in the IFSC, the investment by Entity A is an investment in a person resident outside India (for the limited purpose of FEMA, 1999). Entity A, itself being a person resident in India under FEMA, shall continue to comply with applicable FEMA reporting obligations, including FLA reporting in respect of its outbound investment in Entity B.
(b) Entity B (IFSC entity): For the specific investment made by Entity A into Entity B, Entity B is not required to file the FLA return. Such entity may follow the relevant instructions issued by IFSCA in this matter.
Q20. An entity (entity X) from a foreign jurisdiction has invested in an entity (entity Y) which is regulated by IFSCA. The entity Y in turn invests in an Indian entity (entity Z). Is this transaction treated as foreign investment for entity Z, and what will be the reporting requirement in such a case?
Ans: a) Entity Y (IFSC entity): Investment in entity Y in IFSC will be classified as inward foreign direct investment for the compilation of balance of payment and other external sector statistics. Submission of FLA return by entity Y will be required in terms of the relevant instructions issued by IFSCA for submission of FLA return. Entity Y is not required to file the FLA return with RBI. (Refer Q43).
(b) Entity Z, being a person resident in India under FEMA, shall comply with applicable FEMA reporting obligations issued by RBI, including FLA reporting for inbound investment received from Entity Y.
Note:
1. Entity reports the information only for the financial year April to March; no other financial year allowed.
2. Entity can file the FLA return for any of the previous years, after taking approval from the RBI.
3. The entity can delete/modify the information submitted in the FLA return for earlier periods after taking approval from the RBI. Below are the procedures.
Log in to FLAIR → Go to “Menu” (upper left corner) → Go to “Multiple Year CIN Enable Screen” → select year and submit.
If not able to raise the request, then share the error screenshot at the email ID flareturn@rbi.org.in.
4. No balance sheet or profit and loss accounts need to be submitted as attachments along with FLA Return.
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Author: Ayush Singhal | Email ayushsinghal9266@gmail.com.
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