Form FLA is a mandotory filing requirement with the RBI. Companies that have received foreign direct investment (FDI) or made overseas investments are required to file this return every year — even if their accounts are unaudited or if no new transactions happened during the reporting period.
Noncompliance can attract penalties under FEMA and can disrupt future fundraising, investment structuring, or cross-border transactions.
This article will provide a clear and structured overview of Form FLA — its applicability, due dates, and filing process — so your business stays compliant with RBI regulations.
Form FLA stands for Foreign Liabilities and Assets Return. It is an annual return that Indian companies have to file with the Reserve Bank of India (RBI to report their foreign assets and liabilities, including inward foreign investment (FDI) or outward investment (ODI).
This return captures the financial relationship between Indian entities and non-residents — shareholding patterns, overseas direct investments, and external commercial borrowings (ECBs). It’s not related to taxation but is part of India’s foreign exchange data collection.
The main purpose of Form FLA is to help RBI to maintain an accurate record of India’s international investment position. It helps RBI to monitor:
This data is useful for policy making, macroeconomic analysis and to align with international reporting standards like International Monetary Fund (IMF).
The requirement to file Form FLA is as per Regulation 5(1)(ii) of the Foreign Exchange Management (Transfer or Issue of Security by a Person Resident Outside India) Regulations, 2000. It is part of the Foreign Exchange Management Act (FEMA), 1999, hence it is a statutory compliance.
Form FLA is mandatory for Indian entities with cross-border investments, either by receiving foreign capital or investing abroad. Specifically, the following types of businesses are required to file:
Any company in India that has received FDI in the previous year — even a single inflow — must file Form FLA. This includes equity participation by non-residents, whether active or dormant.
If an Indian company has invested in foreign subsidiaries, joint ventures, or branches abroad, it must report those foreign assets under the FLA Return.
Indian companies that have borrowed funds from overseas lenders must disclose the outstanding liability, even if partial repayments have been made.
Filing is not based on transaction volume or materiality — non-filing is a FEMA violation, regardless of the size or status of the business.
If unsure, check your FDI/ODI history or consult a compliance expert.
Foreign Liabilities and Assets (FLA) Return is to be filed by 15th July every year for the previous financial year (ending 31st March). The deadline is as per the Reserve Bank of India (RBI) and applicable to all Indian entities, whether audited or not.
If audited financials are not available by the deadline, companies can file the return with provisional or unaudited figures. Once audited data is available, the company can revise the return accordingly.
Non-compliance with FLA filing is not just an administrative error — it is a violation under the Foreign Exchange Management Act (FEMA), 1999.
Not filing the form on time can result in:
Under FEMA, non-filing or delayed filing of FLA can attract compounding proceedings. The penalty structure is as follows:
RBI may also ask for detailed explanations and rectification filings before allowing any future capital account transactions.
Filing Form FLA is done entirely online through the FLAIR system (Foreign Liabilities and Assets Information Reporting system) by Reserve Bank of India. Below is the step by step process to help your team stay compliant and avoid common mistakes.
Before you start, ensure the following are in place:
Once logged in:
Missing the 15th July deadline can trigger FEMA penalties and delay future investment-related approvals. Mark your calendar early and assign this responsibility clearly within your finance team.
Form FLA may seem like just another form, but for businesses dealing with foreign investors or cross border transactions, it’s a critical part of being FEMA compliant. At Karbon, we simplify this process by offering end to end support — from helping you understand the RBI’s requirements to ensuring all documentation is in place and ready to file.
Our forex and compliance team works with Indian businesses that receive FDI or make overseas investments, so every detail — from capital structure to regulatory disclosures — is taken care of accurately and efficiently. Whether you’re filing for the first time or need guidance on revised submissions, Karbon provides clarity, speed, and confidence.
If you need expert help with Form FLA or any other RBI reporting, our team is here to assist.
Once you have audited financials, you need to submit a revised Form FLA on the same FLAIR portal. Choose the ‘Revised’ option, upload the updated XML file, and retain proof of submission.
Yes. LLPs receiving FDI or making ODI need to file Form FLA if they have a valid RBI-issued LLP Identification Number and meet the reporting criteria.
Even if there is no FDI, presence of ODI requires you to file Form FLA. This includes equity investment, loans, or guarantees extended to foreign entities.
Yes. Form FLA needs to be filed every year as long as the foreign investment or liability is on your balance sheet — even if there were no transactions during the year.
Yes. Provisional or unaudited numbers can be used initially. Once the audited financials are ready, a revised return needs to be submitted with updated data.
Yes, third-party professionals can file on your behalf. But the login credentials are entity-specific and need to be managed securely. Ultimately, the company is responsible for accurate reporting.
Yes. ECBs are a form of foreign liability and must be disclosed in the appropriate section of the form, even if reported elsewhere under ECB reporting norms.
