Introduction
Foreign investment brings growth opportunities for Indian businesses, but it also brings reporting responsibilities under FEMA.
One such important annual compliance is the Foreign Liabilities and Assets Return, commonly known as FLA Return.
FLA Return is required to be filed by Indian entities that have received Foreign Direct Investment (FDI) on a repatriable basis or have made Overseas Direct Investment (ODI), where such foreign liabilities or foreign assets are outstanding as on 31 March of the reporting year.
For the reporting year 2026, the regular due date for filing FLA Return is 15 July. However, the due date has been extended to 31 July 2026 as per the applicable RBI/FLAIR update. Eligible entities should use this extended window and complete the filing within time.
This article explains the meaning of FLA Return, who needs to file it, due date, RBI FLAIR portal filing process, documents required, consequences of non-filing and practical points to remember.
What is FLA Return?
FLA Return means Foreign Liabilities and Assets Return.
It is an annual return filed with the Reserve Bank of India by Indian entities having foreign liabilities or foreign assets due to FDI or ODI.
In simple words, FLA Return gives RBI information about:
- Foreign investment received by Indian entities
- Overseas investment made by Indian entities
- Foreign liabilities outstanding as on 31 March
- Foreign assets outstanding as on 31 March
- Financial position of the reporting entity
- Country-wise and investor-wise foreign investment details
The purpose of FLA reporting is not merely procedural. The data collected through FLA Return is used by RBI for external sector statistics, Balance of Payments, International Investment Position and foreign investment analysis.
RBI has issued detailed FAQs on Annual Return on Foreign Liabilities and Assets, which explain applicability, reporting requirements and filing process for FLA Return.
FLA Return Due Date for 2026
The regular due date for filing FLA Return is 15 July of every year.
For the reporting year 2026, the due date has been extended to 31 July 2026 as per the applicable RBI/FLAIR update.
Therefore, entities that are required to file FLA Return should complete the filing on or before 31 July 2026.
However, entities should not wait till the last date. Registration on the FLAIR portal, login issues, data preparation, unaudited figures, valuation details and authorised person approval may take time.
Who Needs to File FLA Return?
FLA Return is required to be filed by Indian entities that hold outstanding foreign investment positions as on 31 March of the reporting year.
In practical terms, FLA Return is applicable to:
- Indian companies
- Limited Liability Partnerships (LLPs)
- SEBI registered Alternative Investment Funds (AIFs)
- Partnership firms
- Other Indian-resident entities, wherever applicable
The key condition is that the entity must have:
- Outstanding Foreign Direct Investment (FDI) on a repatriable basis; or
- Overseas Direct Investment (ODI); or
- Both FDI and ODI outstanding as on 31 March of the reporting year.
FLA Return should be reviewed along with other annual compliances of the company. You may also refer to our guide on Annual Compliance for Private Limited Company in India for a broader compliance checklist.
Correct Applicability Test
A common mistake is to assume that FLA Return is required only when fresh FDI or ODI has been received or made during the year.
That is not correct.
The test is not limited to fresh transactions during the year. The test is whether the entity has outstanding foreign liabilities or foreign assets as on 31 March.
Therefore, even if no fresh FDI was received during the year, FLA Return may still be applicable if foreign investment received in earlier years continues to remain outstanding.
Similarly, if an Indian entity has made ODI in earlier years and the overseas investment continues to remain outstanding as on 31 March, FLA Return may be required.
Examples of Entities Required to File FLA Return
Example 1: Company received FDI in earlier year
A private limited company received FDI from a foreign shareholder in FY 2022-23. No fresh FDI was received in FY 2025-26.
If the foreign shareholder continues to hold shares as on 31 March 2026, the company is required to file FLA Return for 2026.
Example 2: LLP received foreign investment
An LLP received capital contribution from a foreign investor on a repatriable basis and such investment is outstanding as on 31 March.
The LLP is required to file FLA Return.
Example 3: Indian company made ODI
An Indian company invested in a foreign subsidiary or joint venture and such investment is outstanding as on 31 March.
The Indian company is required to file FLA Return.
Example 4: No outstanding FDI or ODI
If an Indian entity does not have any outstanding inward FDI or outward ODI as on 31 March of the reporting year or previous year, FLA Return may not be required.
Is FLA Return Required if Accounts Are Not Audited?
Yes. If the accounts are not audited before the due date, the entity should not wait for completion of audit.
FLA Return can be filed on the basis of provisional or unaudited financial statements within the due date.
Once audited financial statements are available, the entity may file revised FLA Return as per the procedure prescribed on the FLAIR portal.
This is an important compliance point. Not filing merely because audit is pending may result in FEMA non-compliance.
Where is FLA Return Filed?
FLA Return is filed online on the RBI FLAIR portal.
FLAIR stands for Foreign Liabilities and Assets Information Reporting system.
The entity must register on the FLAIR portal and complete the return filing through the online reporting system.
Generally, the process involves:
- Registration of entity on FLAIR portal
- Uploading authority letter and verification letter
- Receiving user credentials
- Login by authorised person
- Filling entity details
- Reporting financial figures
- Reporting FDI and/or ODI details
- Submission of FLA Return
- Downloading acknowledgement
FLA Return is filed online through the RBI FLAIR Portal, which is the official reporting system for Foreign Liabilities and Assets Information Reporting.
Documents and Data Required for FLA Return Filing
Before starting the filing process, the entity should keep the following details ready:
- CIN / LLPIN / registration details
- PAN of the entity
- Registered office details
- Authorised person details
- Previous year and current year financial statements
- Audited financial statements, if available
- Provisional financial statements, if audit is pending
- Details of foreign shareholders
- Country of foreign investor
- Percentage of foreign holding
- FDI amount received
- Details of ODI, if any
- Foreign subsidiary / joint venture details
- Reserves and surplus
- Paid-up capital
- Profit or loss figures
- Other capital details, where applicable
- Authority letter
- Verification letter
The data should be reviewed carefully before submission because incorrect reporting may require revision approval.
Step-by-Step Process for FLA Return Filing
Step 1: Check Applicability
First, check whether the entity has outstanding FDI or ODI as on 31 March.
If there is no outstanding FDI or ODI, check whether there was any such position in the previous year because FLA captures data for two years.
Step 2: Register on FLAIR Portal
If the entity is filing for the first time, registration on the RBI FLAIR portal is required.
The entity needs to provide basic details and upload required documents such as authority letter and verification letter.
Step 3: Login to FLAIR Portal
After successful registration, user credentials are sent to the authorised person.
The authorised person can then log in and access the FLA Return form.
Step 4: Fill Entity Details
Basic information of the entity must be entered, including name, registration number, PAN, contact details and business activity.
Step 5: Enter Financial Details
Financial figures should be entered based on audited or unaudited financial statements, as applicable.
Care should be taken while entering capital, reserves, profit/loss and net worth-related information.
Step 6: Report FDI Details
If the entity has received foreign investment, details of foreign investor, country, percentage holding and investment amount should be reported.
Step 7: Report ODI Details
If the entity has made overseas investment, details of foreign subsidiary, joint venture or overseas entity should be reported.
Step 8: Review and Submit
Before submission, the return should be reviewed carefully.
After submission, acknowledgement should be saved for records.
Consequences of Non-Filing of FLA Return
Non-filing of FLA Return within the due date is treated as a violation under FEMA.
The entity may be exposed to:
- Late submission fee
- Regulatory correspondence
- Compounding requirement
- Penalty under FEMA
- Compliance issues in future foreign investment transactions
- Due diligence observations during funding, audit or transaction review
Therefore, FLA Return should not be treated as a routine formality. It is an important FEMA compliance for entities having FDI or ODI.
Apart from FEMA reporting, companies should also ensure timely ROC annual filings. If your company has missed ROC filings, read our detailed guide on ROC Annual Filings Not Done? Penalties, Consequences & How to Fix Them.
Common Mistakes in FLA Return Filing
Many entities make avoidable mistakes while filing FLA Return.
Some common mistakes include:
- Assuming FLA is required only when fresh FDI is received
- Not filing because accounts are unaudited
- Ignoring ODI reporting
- Incorrect classification of FDI and other capital
- Not reporting foreign liabilities properly
- Using incorrect country or investor details
- Not keeping acknowledgement safely
- Filing without reviewing previous year data
- Missing revision after audit completion, where required
Professional review helps reduce the chances of errors and future compliance issues.
FLA Return and Startups
Many startups receive foreign investment at an early stage and then forget annual FEMA reporting obligations.
Even if the startup has no further funding round during the year, FLA Return may still be applicable if foreign shareholding continues as on 31 March.
Startups with foreign shareholders should review:
- FDI received
- FC-GPR filing status
- Shareholding pattern
- Foreign investor details
- Valuation and financial figures
- FLA Return filing status
This is especially important before fundraising, due diligence, acquisition, conversion, merger or strike off.
Startups receiving foreign investment should also ensure that their company incorporation, shareholding structure and FEMA reporting are properly aligned from the beginning. You may also read our guide on Private Limited Company Registration in India for understanding the basic company setup process.
FLA Return and LLPs
FLA Return is not limited to companies.
LLPs having foreign investment on a repatriable basis may also be required to file FLA Return.
Therefore, LLPs with foreign capital contribution should also check applicability and file within the extended due date.
FLA Return and ODI
Indian entities that have made overseas investment are also covered.
If an Indian company or LLP has invested in a foreign subsidiary, joint venture or overseas entity and such investment is outstanding as on 31 March, FLA Return may be required.
ODI reporting should not be ignored because FLA Return covers both foreign liabilities and foreign assets.
Need Assistance in FLA Return Filing?
FLA Return filing requires careful review of FEMA applicability, foreign investment position, financial statements and RBI portal reporting.
Legnex Solutions can assist you with:
- FLA Return applicability check
- RBI FLAIR portal registration
- FLA Return filing
- FDI and ODI reporting review
- Provisional filing based on unaudited figures
- Revised FLA Return support
- FEMA compliance advisory
- End-to-end foreign investment reporting support
If your company, LLP or entity has outstanding FDI or ODI as on 31 March, you should complete the FLA Return filing within the extended due date.
Conclusion
FLA Return Filing 2026 is an important FEMA compliance for Indian entities having outstanding FDI or ODI as on 31 March of the reporting year.
For 2026, the due date has been extended to 31 July 2026 as per the applicable RBI/FLAIR update.
Entities should not delay the filing merely because accounts are unaudited. Provisional figures can be used, and the return can be revised later after audit, wherever required.
Timely filing helps avoid FEMA non-compliance, late submission issues and future complications during funding, due diligence or foreign investment transactions.
Frequently Asked Questions (FAQs) ?
What is FLA Return?
FLA Return means Foreign Liabilities and Assets Return. It is an annual return filed with RBI by Indian entities having outstanding FDI or ODI as on 31 March of the reporting year.
Who is required to file FLA Return?
All Indian-resident entities such as companies, LLPs, AIFs, partnership firms and other eligible entities having outstanding FDI and/or ODI as on 31 March are required to file FLA Return.
What is the due date for FLA Return Filing 2026?
The regular due date is 15 July. For the reporting year 2026, the due date has been extended to 31 July 2026 as per the applicable RBI/FLAIR update.
Is FLA Return required if there is no fresh FDI during the year?
Yes, if foreign investment received in earlier years continues to remain outstanding as on 31 March, FLA Return may be required even if there is no fresh FDI during the year.
Is FLA Return applicable to LLPs?
Yes. LLPs having outstanding foreign investment on a repatriable basis may be required to file FLA Return.
Can FLA Return be filed with unaudited financial statements?
Yes. If audited financial statements are not available before the due date, FLA Return can be filed using provisional or unaudited figures. Revised filing can be done later as per the FLAIR portal procedure.
Where is FLA Return filed?
FLA Return is filed online through the RBI FLAIR portal.
What happens if FLA Return is not filed?
Non-filing of the FLA return within the due date is treated as a FEMA violation and may attract a late submission fee, penalty, or other regulatory consequences.