FLA Annual Return to RBI

FLA Annual Return to RBI
for FDI Companies

15 July, FLAIR Portal, Every Year — No Exceptions

The Foreign Liabilities and Assets (FLA) Annual Return is the most-missed FEMA filing by Indian companies with foreign investment. The threshold is zero — even a single share held by a non-resident on 31 March triggers the filing requirement. The deadline of 15 July is fixed, the FLAIR portal interface is straightforward, and the penalties for missing it (Late Submission Fees that escalate steeply with delay) are entirely avoidable.

Who Must File — The Threshold Is Zero
  • Every Indian company (Pvt Ltd, Ltd, OPC) that has received any FDI at any time, even prior years.
  • Every Indian LLP, partnership firm or trust with foreign liability or asset on its balance sheet during the FY.
  • Every Indian entity that has made any ODI — investment in a foreign JV or WOS.
  • Branch Offices, Liaison Offices and Project Offices of foreign companies (foreign liability angle).
  • Even if FDI was received years ago and the foreign investor has long since exited, FLA is required for as long as any non-resident-issued instrument is outstanding.
Information Required to File FLA
Entity-level data
  • CIN, PAN, registered address, contact details.
  • Reporting FY and balance sheet date.
  • Type of entity (Pvt / Pub / LLP / trust).
  • Listing status and stock exchange.
FDI / ODI data per investor / investee
  • Country of investor / investee.
  • Currency of original transaction (USD, EUR, GBP, etc.).
  • Instrument type (equity / CCD / CCPS / preference).
  • First allotment date, % shareholding, paid-up value, market value year-end.
  • Dividend declared during the year.
The Filing Process — FLAIR Portal
  1. Entity user registration on FLAIR portal (one-time) with CIN and authorised contact email.
  2. Log in & select reporting FY.
  3. Populate Entity Profile (carries forward from prior year if first FLA already filed).
  4. Enter FDI section: details of each non-resident investor, instrument-wise position at year-end.
  5. Enter ODI section if any overseas investment made.
  6. Enter P&L impact section: dividend declared, FX impact.
  7. Submit: portal generates acknowledgment with reference number; save for record.
Common Mistakes We See
  • Forgetting that legacy FDI still triggers filing — even if all foreign investors exited 5 years ago, if any non-resident-issued instrument remains outstanding (CCD not yet converted, preference shares outstanding) the company must file.
  • Filing in INR instead of original transaction currency — FLA captures the currency of the original allotment; entries must reflect USD / EUR / SGD as appropriate.
  • Filing on unaudited numbers and not revising after audit — the unaudited-then-revised path is explicitly allowed but many companies forget the September revision and the figures end up wrong on record.
  • Year-end market value missing — unlisted companies use Net Asset Value or recent valuation; this is not optional.
Our FLA Service
  • Annual filing of FLA Return by the 15 July deadline.
  • First-FLA entity registration on FLAIR portal for newly incorporated foreign-owned companies.
  • Retrospective filing for years missed with LSF computation and AD Bank coordination.
  • Revision filing post-audit if first submission was on unaudited figures.

Engage us ahead of the 15 July deadline for hassle-free annual FLA filing, or for retrospective filing of missed historical years.