FLA Return Filing Due Date for FY 2025-26: 15 July 2026

Indian entities having foreign investment or overseas investment must review their obligation to file the Annual Return on Foreign Liabilities and Assets, commonly known as the FLA Return. For the financial year ended 31 March 2026, the return must be submitted to the Reserve Bank of India by 15 July 2026.

Who Is Required to File the FLA Return?

According to the RBI’s updated FAQs on the Annual Return on Foreign Liabilities and Assets under FEMA, 1999, the filing requirement applies to entities that have received Foreign Direct Investment or made Overseas Direct Investment during the current or any previous financial year and have reportable foreign assets or liabilities.

The covered entities include:

• Companies and other entities covered under Section 1(4) of the Companies Act, 2013;

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• Limited Liability Partnerships registered under the LLP Act, 2008;

• SEBI-registered Alternative Investment Funds;

• Partnership firms and proprietary concerns;

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• Public-private partnerships; and

• Other eligible Indian entities having inward or outward foreign investment.

The applicability should be checked based on outstanding FDI or ODI as at 31 March 2026 or 31 March 2025 because the FLA Return captures data for both the current and previous reporting years.

Due Date and Reporting Period

The FLA Return for FY 2025-26 must be filed by 15 July 2026. It reports the entity’s foreign liabilities and assets as at the end of March 2026.

The return must be filed even where the financial statements have not been audited by the due date. In such cases, the entity may use provisional or unaudited figures and subsequently seek RBI approval through the FLAIR portal to submit a revised return after the audited financial statements become available.

How Is the FLA Return Filed?

The return is filed electronically through the RBI’s Foreign Liabilities and Assets Information Reporting portal, known as the FLAIR portal.

A first-time filer must register on the portal and upload the prescribed verification and authority letters. After registration, the authorised person can log in and submit the applicable financial and foreign-investment details. The earlier email-based reporting system was replaced by the web-based FLAIR system from June 2019 under the RBI circular dated 28 June 2019.

When Is Filing Not Required?

The FLA Return is generally not required where the entity has no outstanding inward or outward direct investment as at the end of both the current and previous reporting years. Receipt of only foreign share application money, without outstanding FDI or ODI, also does not independently trigger the filing requirement.

Consequences of Non-Filing

The RBI states that failure to submit the return by 15 July constitutes a contravention under the Foreign Exchange Management Act, 1999. The penalty provisions may be invoked, and delayed filings may require payment of the applicable Late Submission Fee or other regularisation action.

Entities should verify their foreign shareholding, overseas subsidiaries, joint ventures and other cross-border investments well before the deadline.

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