Indian companies with FDI, ODI or foreign holdings must file the annual FLA return on RBI's FLAIR portal by 15 July under FEMA — FY 2026-27 guide.
The Annual Foreign Liabilities and Assets (FLA) Return is RBI's statistical lifeline for measuring India's cross-border investment position. For FY 2026-27, every Indian company, LLP and Alternative Investment Fund that has received Foreign Direct Investment, made Overseas Direct Investment, or holds any foreign asset or liability outstanding on 31 March must file the FLA Return by 15 July of the following year on the RBI FLAIR portal.
Who Must File
- Companies registered under the Companies Act 2013 that have received FDI or made ODI in any year, even if no transaction in the reporting year.
- Limited Liability Partnerships that have received FDI or made ODI.
- Partnership firms, branches and project offices holding foreign assets or liabilities.
- Alternative Investment Funds and Investment Vehicles with foreign capital.
- Entities that issued ADR / GDR / FCCB outstanding as of 31 March.
Filing Deadline and Mechanism
The FLA Return is due by 15 July each year for outstanding positions as on 31 March. Filing is done through the RBI FLAIR (Foreign Liabilities and Assets Information Reporting) portal. Entities first register with a user ID, then upload the annual return in the prescribed format. If audited accounts are not finalised by 15 July, file with unaudited figures and submit a revised return by 30 September.
Key Data Points Captured
The return captures equity capital, reserves and surplus, retained earnings, foreign liabilities (FDI, ECB, trade credit, equity capital, portfolio investment) and foreign assets (ODI, overseas branches, portfolio investment, loans receivable). RBI uses the aggregated data to compile India's International Investment Position and Balance of Payments statistics, published quarterly.
Non-Filing Consequences
- Treated as a contravention under FEMA section 13 attracting penalty up to thrice the sum involved or ₹2 lakh, whichever is higher.
- Continuing offence attracts additional ₹5,000 per day during persistence.
- Compoundable under FEMA — RBI Compounding Authority can impose graded fines.
- Restriction on further FDI inflows or ODI approvals until compliance is regularised.
- MCA filings such as AOC-4 may flag the contravention for audit committee disclosure.
Common Errors to Avoid
Reporting fully diluted shareholding instead of paid-up; missing branch and project office data; ignoring outward FDI in step-down subsidiaries; misclassifying ECBs as FDI; using book value where market value is required for listed entities. Each error becomes a discrepancy in the RBI scrutiny matrix.
Conclusion
FLA filing is a low-effort, high-risk compliance — the data is informational but penalties for missing it are real. Diarise 15 July in your annual compliance calendar, reconcile with AOC-4 and FC-GPR filings, and treat FLAIR as part of your treasury closing.
