FLA Form Filing Guide: Requirements, Process, and Due Dates

If your Indian company or LLP has received foreign investment or invested outside India, filing the Foreign Liabilities and Assets (FLA) form is a compliance you cannot ignore. This RBI-mandated disclosure captures your foreign shareholding and overseas investments as of 31 March each year.

The purpose is simple: it helps the Reserve Bank of India monitor Foreign Direct Investment (FDI) and Overseas Direct Investment (ODI) flows and assess India’s external financial position. Since the move to the web-based FLAIR portal, all filings must be completed online, with no offline or email submissions allowed.

The deadline is strict—15 July every year. Missing it can trigger penalties under FEMA, even if there were no transactions during the year.

What Is the FLA Form?

The FLA Form, formally called the Foreign Liabilities and Assets Return, is an annual reporting requirement introduced by the Reserve Bank of India. If your business has any foreign investment exposure, this return becomes part of your yearly compliance routine.

• It covers FDI and overseas investments made, whether active or outstanding as on 31 March.
• The legal requirement flows from the Foreign Exchange Management Act (FEMA), 1999, which governs all cross-border transactions in India.
• Unlike event-based filings, the FLA Return is a statistical disclosure, used by the RBI to track India’s international financial assets and liabilities.

Who Needs to File the FLA Return?

Entities With Foreign Direct Investment

• Indian companies that received FDI during the financial year.
• Companies with outstanding foreign shareholding from earlier years, even if there was no fresh inflow.
• LLPs that received capital contribution or profit share from non-residents.

Entities With Overseas Direct Investment

• Indian entities that invested in joint ventures (JV) or wholly owned subsidiaries (WOS) outside India.
• Businesses holding any overseas financial assets, including equity and loans.
• Applicable even if the foreign entity is dormant or not yet generating revenue.

Who Is Exempt from Filing?

• Companies that issued shares to non-residents only on a non-repatriable basis.
• Entities with no FDI or ODI outstanding as of 31 March.
• Companies that only received share application money without allotment (these are reported elsewhere; FLA focuses on assets and liabilities actually held).

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Critical Due Dates and Timelines

Standard Filing Deadline

• The standard FLA return due date is 15 July every year.
• The return must capture foreign assets and liabilities as on 31 March of the same year.
• If you do not file by the July 15 deadline, the RBI treats the entity as non-compliant, regardless of audit status.

Filing With Unaudited Accounts

• If your audit is not complete by July 15, you may file the FLA return using unaudited (provisional) figures.
• This allows you to meet the deadline and avoid penalties.
• After audit completion, you must submit a revised return with final numbers.
• The revised filing must be completed by 30 September, with no separate RBI approval required.

Prerequisites for Filing on the FLAIR Portal

Required Documents

• Audited or provisional financial statements for the previous financial year.
• Verification Letter, in the prescribed format available on the FLAIR portal.
• Authority Letter authorising the individual filing the return.
• PAN and Corporate Identification Number (CIN) / LLP identification number of the entity.
• Foreign investment details, including investor names, country of residence, and percentage holding.

Registration on the FLAIR System

• Access the RBI’s FLAIR system.
• Complete the User Registration Form for new entities.
• Fill in the details in the FLA user registration form, upload the required documents (Verification Letter and Authority Letter), and click Submit to complete the registration.
• After review, the user ID and default password are sent to the authorised person’s email address.

How to File FLA Return Step-by-Step?

Step 1: Login and Dashboard Navigation

• Log in to the FLAIR portal using the credentials issued by the Reserve Bank of India.
• Enter the OTP sent to your registered email ID or mobile number.
• After login, go to the ‘FLA Online Form’ section on the dashboard.
• Choose the relevant financial year and click ‘Start Filing FLA Form’.

Step 2: Filling Company and Financial Details

• Review the auto-filled details such as PAN, CIN/LLPIN, and registered address.
• Enter key financial figures:
  • Paid-up capital
  • Reserves and surplus
  • Sales or turnover
• Select the correct NIC-2008 industry code that best matches your core activity.
• Specify whether the filing is based on provisional (unaudited) or audited accounts.

Step 3: Reporting Foreign Assets and Liabilities

• Report FDI details for foreign shareholding or capital contribution in India.
• Enter ODI information for overseas joint ventures or subsidiaries.
• Disclose Other Capital, such as inter-company loans or receivables.
• Cross-check all figures with your balance sheet as of 31 March.

Step 4: Validation and Submission

• Click ‘Validate’ to check for missing fields or data mismatches.
• Resolve any errors flagged by the system.
• Once validated, click ‘Submit Return’ to complete the filing.
• Download and save the acknowledgement and PDF copy for records.

Penalties for Non-Compliance

Missing the FLA filing deadline is not treated as a minor delay. The RBI views it as a contravention of FEMA provisions, even when there was no fresh foreign investment during the year. The longer the delay, the higher the exposure.

• Late or non-filing attracts monetary penalties under FEMA for failure to report foreign liabilities and assets.
• For standard delays, the RBI levies a flat Late Submission Fee (LSF) of ₹7,500 per return.
• In more serious or prolonged cases, penalties may include a base amount, along with a daily fine for continuing default (often cited at around ₹5,000 per day, subject to adjudication).
• Persistent non-compliance can trigger regulatory scrutiny, especially for entities with recurring foreign investment activity.
• To regularise the default, the entity must apply for compounding, a formal process where the violation is settled after payment.
• Compounding applications are handled by the jurisdictional regional office of the RBI and may involve document review and a personal hearing.

Common Mistakes to Avoid

• Mixing Up FLA With APR: The FLA return applies to all entities with FDI or ODI. The Annual Performance Report (APR) is separate and applies only to overseas JVs and WOS.
• Waiting for Audited Accounts: Delaying the filing until audit completion often leads to missing the July 15 deadline. You should file using provisional numbers and revise later.
• Incorrect Reporting of Share Application Money: Share application money pending allotment should not be treated as equity in the FLA return. Misreporting here can trigger scrutiny.
• Using an Incorrect or Inactive Email ID: OTPs and system alerts go to the registered email. A wrong ID can block access close to the deadline.
• Skipping Filing When There Are No New Transactions: Even with no activity during the year, a return is mandatory if any foreign assets or liabilities remain outstanding.

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Conclusion

The FLA Return is not just a routine filing—it is a core part of staying compliant with FEMA regulations when your business has foreign investments. Filing it on time helps you avoid penalties, compounding procedures, and unnecessary regulatory attention. With a clear 15 July deadline, planning ahead is essential, especially for businesses with recurring FDI or overseas investments.

If final accounts are not ready, you can still file using provisional financials and revise later. Keeping your foreign investment records updated, documents organised, and FLAIR portal access active makes the process far smoother. Over time, consistent and accurate reporting of foreign liabilities and assets also helps when you seek future approvals or interact with regulators and banks.

FAQs

Q1. Is the FLA return mandatory for LLPs?

Yes. LLPs must file the FLA return if they have received FDI or made ODI and have any outstanding foreign assets or liabilities.

Q2. What is the due date for filing the FLA return?

The standard deadline is 15 July every year. If audited accounts are not ready, you must file using provisional figures by this date and submit a revised return by 30 September.

Q3. What is the penalty for late filing of the FLA return?

Late filing attracts a Late Submission Fee of ₹7,500 per return. Continued default is treated as a FEMA contravention and may lead to penalties up to 300% of the amount involved or ₹2,00,000 where the amount cannot be quantified.

Q4. Can I file the FLA return with unaudited accounts?

Yes. The RBI allows filing with provisional (unaudited) financials to meet the July deadline, provided you revise the return with audited figures by 30 September.

Q5. How do I register on the FLAIR portal?

Register on the RBI’s FLAIR portal by uploading the Verification Letter and Authority Letter (formats available on the portal). After approval, the Reserve Bank of India shares login credentials via email.