Who files, and who does not
The test is the balance sheet, not the year's transactions.
| Situation at 31 March | FLA return due by 15 July? |
|---|---|
| Company holds foreign direct investment received in any earlier year, with nothing new this year | Yes |
| Company received its first FDI during the year | Yes |
| Company or LLP holds overseas direct investment abroad | Yes |
| LLP has foreign capital contribution outstanding | Yes |
| SEBI-registered Alternative Investment Fund with foreign investment | Yes |
| Partnership firm or public private partnership holding foreign assets or liabilities | Yes |
| No outstanding inward or outward investment at end-March of this year and of the previous year | No |
| Only share application money received, with no outstanding foreign investment | No |
| Foreign investor holds shares bought from a resident, and the company itself never issued to a non-resident | Yes, the holding is a foreign liability of the company |
If in doubt, look at the shareholding pattern and the investment schedule rather than the bank statement. Money that never moved this year does not end the obligation.
Fees
Professional fee: on quote. The return is priced on the number of foreign investors and overseas entities, and on whether earlier years also have to be filed.
Government fee: none. Filing the FLA return on the FLAIR portal is free.
Late filing, kept separate because it is not a filing fee:
| Situation | What applies |
|---|---|
| Return filed by 15 July | Nil |
| Return filed late | Non-filing by the due date is treated as a violation of FEMA. The delay is regularised by a Late Submission Fee, which is paid through the Foreign Exchange Department of the RBI regional office for the entity's registered office |
| Late Submission Fee amount for recurring returns such as the FLA | ₹7,500 flat, under the RBI late submission fee framework |
| Due date more than three years old | The LSF route closes and the default is regularised by compounding with the Reserve Bank |
Professional fees exclude GST at 18%. Government fees, where they apply, are paid at actuals to the department and are shown separately. Fees verified on 22 September 2026.
Getting on to the FLAIR portal
Most FLA problems in July are login problems, not accounting problems.
| Step | What happens |
|---|---|
| 1 | On the FLAIR portal at flair.rbi.org.in, choose Registration for New Entity Users |
| 2 | Fill the registration form and upload the verification letter and the authority letter for the authorised person |
| 3 | The Reserve Bank processes the registration |
| 4 | The user ID and a default password are emailed to the authorised person |
| 5 | Log in, change the password and check that the entity details match your records |
| 6 | File the return for the financial year ended 31 March |
Two practical points. The authorised person named in the registration receives the credentials, so use an email address that will still exist next July. And an entity that has changed its name, CIN or authorised person should correct the entity details before filing, not while filing.
What the return asks for
The FLA return is a statistical return, so the Reserve Bank wants comparable figures for two dates: 31 March of the reporting year and 31 March of the previous year.
Keep these ready before you start.
- Balance sheet for the year, audited if available, otherwise provisional.
- Paid-up capital split between residents and non-residents, with the number of shares held by each non-resident.
- Reserves and surplus, and the resulting net worth.
- Foreign direct investment received, instrument by instrument, with the country of the investor.
- Overseas direct investment made, entity by entity, with the country.
- Any other foreign liabilities and assets, such as trade credit or borrowings from a group entity abroad.
- Sales and purchases figures for the year, and export and import figures where there are any.
Where accounts are provisional, note in your own records which figures will change, because the revised return has to be filed once the audit is done.
How the FLA return sits with your other FEMA filings
The FLA return is annual and cumulative. The FIRMS filings are event-based and one-off. One does not substitute for the other.
| Filing | Trigger | Portal | Due |
|---|---|---|---|
| FC-GPR | Issue of equity instruments to a non-resident | FIRMS | 30 days from allotment |
| FC-TRS | Transfer of shares between a resident and a non-resident | FIRMS | 60 days from the transfer or receipt of funds, whichever is earlier |
| LLP(I) | Foreign capital contribution to an LLP | FIRMS | 30 days from receipt |
| FLA return | Foreign liabilities or assets on the books at 31 March | FLAIR | 15 July |
A company that raised a round in February files FC-GPR by March and the FLA return by 15 July, for the same investment. Missing the second one is the most common FEMA default we see in diligence. See FC-GPR filing and FDI reporting for the event-based side, and legal and secretarial due diligence for what a buyer looks at.