FLA Return Filing
The annual foreign liabilities and assets return required from companies holding or issuing overseas investment.
The annual return on foreign liabilities and assets is filed with the Reserve Bank by every Indian company, LLP or entity that has received foreign direct investment or made overseas direct investment, in any year. It is due by 15 July for the financial year just ended.
It is one of the most commonly missed filings among companies with foreign shareholding, because it sits outside the Companies Act calendar entirely and nobody in the ROC compliance cycle is watching for it.
What this costs
RBI Compliance
₹18,904 plus GST
- Annual FLA Return Filing
- RBI Compliance Support
Who must file
- Companies that have received foreign direct investment at any time
- Companies that have made overseas direct investment at any time
- Limited liability partnerships with foreign investment
- Other entities holding foreign assets or liabilities, including alternative investment funds
- The obligation continues in later years even where no fresh investment is received
- Filing is required even where the foreign investment has since been fully divested during the year
Unaudited accounts are acceptable
The return is due by 15 July, which is well before most companies finalise their audit. The Reserve Bank permits filing on the basis of unaudited or provisional figures for that reason.
Where the audited figures subsequently differ, a revised return must be filed by the end of September. Waiting for the audit rather than filing provisionally is the usual reason the July deadline is missed.
What the return reports
- Foreign direct investment received, by investor country and by instrument
- Overseas direct investment made, if any
- Shareholding pattern showing resident and non-resident holdings
- Financial details — paid-up capital, reserves, sales and purchases
- Value of foreign assets and liabilities at the beginning and end of the year
- Details of any disinvestment during the year
Non-filing is a FEMA contravention
Failure to file is a contravention of the Foreign Exchange Management Act, which is regularised through compounding rather than by simply filing late.
Compounding involves an application to the Reserve Bank, a penalty determined case by case, and a process that takes months. It is disproportionately expensive relative to the filing itself, which is free and takes days.
How we handle it
- 1 Confirming applicability We check whether the entity has ever received foreign investment or made overseas investment, since the obligation persists across years.
- 2 Portal registration The entity is registered on the Reserve Bank reporting portal where this has not been done before.
- 3 Compiling the data Financial figures, shareholding and foreign asset and liability positions are compiled for both year ends.
- 4 Filing by 15 July The return is filed on provisional figures where the audit is not complete, which is expressly permitted.
- 5 Revised filing Where audited figures differ, the revised return is filed by the end of September.
- 6 Diarising The July deadline is recorded so the return is not missed in future years.
Frequently asked questions
Do we file if no fresh investment came in this year?
Yes. The obligation continues for every year in which foreign assets or liabilities are outstanding, not just the year the investment was received.
Our audit is not done by 15 July. What do we do?
File on provisional or unaudited figures, which the Reserve Bank expressly permits, and file a revised return by end September if the audited figures differ. Waiting for the audit is how the deadline gets missed.
What if we never filed at all?
Non-filing is a FEMA contravention regularised through compounding, which involves an application, a penalty and a process taking months. It should be addressed rather than left.
Does this apply to an LLP?
Yes. LLPs with foreign investment file the return in the same way as companies.
Is this the same as FC-GPR?
No. FC-GPR reports a specific allotment of shares to a foreign investor within thirty days. The FLA return is an annual position statement of all foreign assets and liabilities.
What is not included. Government fees, statutory charges, stamp duty, court and registry fees, digital signature costs and any third-party professional charges are separate and payable at actuals. GST applies on professional fees where indicated. Prices shown are indicative and may change without notice; we confirm the total in writing before any work begins — see our terms on pricing.
Talk to us about FLA Return Filing
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- Expert document checking before submission
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