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The Classic Partners LLP · FEMA & RBI

FLA Return Filing

One annual return to the RBI, due 15 July, owed by every entity that has ever received foreign investment — including in years when nothing happened.

Quick answer

The Foreign Liabilities and Assets return is an annual return filed with the RBI by 15 July each year by any Indian company, LLP or other entity that has received foreign direct investment or made overseas direct investment in any previous year, including years in which there was no fresh transaction. It is filed on the RBI's FLAIR portal based on the entity's audited accounts, and where accounts are not yet audited, unaudited figures can be filed by the deadline and revised later.

What we cover

What our FLA return service covers

Applicability, registration, filing and revision.

  • Assessing whether the entity is liable to file at all
  • Registration of the entity and authorised person on the FLAIR portal
  • Preparing the return from audited or provisional financial statements
  • Reporting foreign liabilities and foreign assets at the correct valuation
  • Filing by 15 July and revising once accounts are audited
  • Regularising earlier years where the return was never filed
Key components

What the return reports

A statistical return with real consequences for getting it wrong.

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Foreign liabilities

Foreign direct investment received, including equity and other capital held by non-residents in the reporting entity.

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Foreign assets

Overseas direct investment made by the entity, and other assets held outside India.

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Two reference dates

Positions and transactions reported for both the previous and the latest financial year, with opening and closing figures.

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Revision

The facility to file on provisional numbers by the deadline and revise once audited figures are available.

How we work

Our process

A short annual process with a fixed date.

1

Applicability check

Confirming whether foreign investment or overseas investment exists on the books at any point.

2

FLAIR registration

Registering the entity and its authorised person, which has to be done before the first filing.

3

Preparation

Extracting the required figures from the financial statements at the correct valuation basis.

4

Filing and revision

Submitting by 15 July, then revising with audited figures if provisional numbers were used.

Why choose us

Why the FLA return gets missed

What sets our approach apart.

It survives the transaction

Entities file FC-GPR once and assume reporting is complete; the FLA return continues every year for as long as the investment stays on the books.

July is early

The 15 July deadline usually falls before the audit is complete, so entities wait for audited numbers and miss the date entirely.

Non-filing is a contravention

Failure to file is a contravention under FEMA and is dealt with through compounding, which is more expensive and slower than filing on provisional numbers.

FAQs

FLA Return Filing questions answered

What people ask before engaging us.

Any Indian company, LLP or other entity that has received foreign direct investment or made overseas direct investment in the current or any previous year, and still has such investment on its books. If a company received FDI five years ago and nothing has changed since, it still files every year.
15 July each year, for the financial year ended on the preceding 31 March. Where the return is filed on unaudited figures, a revised return based on the audited accounts is to be submitted subsequently.
Yes, as long as foreign investment or overseas investment remains outstanding on the balance sheet. The return reports positions, not just transactions, so a year with no activity still requires a filing.
The return should still be filed by the deadline using provisional or unaudited figures, and then revised once the accounts have been audited. Waiting for the audit and missing the deadline creates a contravention that provisional filing would have avoided.

Never filed an FLA return?

We will check your applicability for each past year and tell you how to regularise it.

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