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FEMA and RBI|Glossary entry|3 min read

FLA Return

Foreign Liabilities and Assets Return/Annual Return on FLA

Annual RBI filing reporting foreign liabilities and assets of Indian companies; due 15 July each year.

Filing window

15 July of every calendar year

Regulator

Reserve Bank of India (RBI)

Regulator

Reserve Bank of India (RBI)

Deadline

15 July of every calendar year, for the preceding financial year ended 31 March

Penalty

Late or non-filing is a FEMA contravention...

Legal basis

Foreign Exchange Management Act, 1999

§ 01
Definition

What is FLA Return?

The Annual Return on Foreign Liabilities and Assets (FLA Return) is a mandatory filing by every Indian company that has received Foreign Direct Investment or made Overseas Direct Investment in any prior year, including the year of reporting. The return is filed online through the RBI's FLAIR (Foreign Liabilities and Assets Information Reporting) portal and provides RBI with consolidated data on the company's foreign equity, debt, and assets.

Unlike FC-GPR which is event-triggered, FLA is an annual statutory return covering the financial year ended 31 March, due by 15 July of the same calendar year. The return must be based on audited financial statements. Where audited accounts are not finalised by 15 July, the return is filed on unaudited figures and revised within a stipulated window once audit completes.

Applies to
  • +All Indian companies that have received FDI in any prior year
  • +Indian companies that have made Overseas Direct Investment
  • +Foreign-owned subsidiaries operating in India
  • +Indian LLPs with foreign investment
§ 02
Citation

Statutory basis

Foreign Exchange Management Act, 1999

Section 11(2)

Rule reference

FEMA Notification No. 22(R)/2016-RB; RBI Circular on FLAIR portal

Notification

RBI Master Direction No. 18/2015-16 (as amended)

Enforced by

Reserve Bank of India (RBI), through FLAIR portal

Citations are editorially curated. Always verify current applicability with qualified Indian counsel before acting on a specific matter.

§ 03
Why it matters

The stake

15 July of every calendar year

Filing window for FLA Return. Skipping or mishandling this compliance carries direct financial and operational consequences.

Why FLA Return matters for your GCC

FLA is a recurring compliance that catches GCCs off-guard because it is annual rather than event-driven. Many newly-incorporated foreign subsidiaries forget the 15 July deadline in their first operational year. RBI uses FLA data to monitor cross-border capital flows; a missed filing flags the entity for compliance scrutiny and can delay routine FEMA approvals for years.

§ 04
Pitfalls

The 4 ways FLA Return goes wrong

Real scenarios from real GCC compliance audits. Each one preventable.

01

Trap 01

Treating FLA as optional when the company has not yet received fresh FDI in the reporting year; it remains mandatory if FDI was received in any prior year

02

Trap 02

Filing on unaudited figures and forgetting to revise after audit completion within the prescribed window

03

Trap 03

Mismatching figures with the company's audited balance sheet, triggering RBI queries

04

Trap 04

Missing the 15 July deadline due to the financial year-end audit timeline; advance preparation is essential

§ 05
IRPR Network handles this

Done for you

FEMA and RBI Compliance Service

irpr.network prepares and files FLA Return on FLAIR every year, coordinates with your statutory auditor for figure reconciliation, and tracks the revision window post-audit.

Our workflow

  1. 01Identify the trigger event in your GCC operations
  2. 02Prepare and validate the FLA Return filing or compliance step
  3. 03Submit to the regulator and obtain acknowledgement
  4. 04Track in your compliance calendar for ongoing or recurring obligations
§ 07
Questions

Asked about FLA Return

4 specific questions that GCC operators ask most often, answered with citations to the relevant regulations.

Need help with FLA Return?

IRPR Network manages FLA Return as part of FEMA and RBI Compliance Service, with a zero-penalty guarantee.

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Q01

Is FLA Return required if the company received FDI only once, several years ago?

+

Yes. FLA is a mandatory annual filing for any Indian company that has received FDI at any point in its history, even if there has been no fresh capital infusion in the reporting year. The obligation continues for as long as the foreign-held capital instruments remain outstanding.

Q02

What is the difference between FC-GPR and FLA Return?

+

FC-GPR is filed within 30 days of each individual share allotment to a foreign investor. FLA Return is an annual filing aggregating all foreign assets and liabilities as of 31 March each year, due by 15 July. A company files multiple FC-GPRs during the year (one per allotment) and one FLA annually.

Q03

What happens if 31 March audited accounts are not ready by the 15 July FLA deadline?

+

The company files FLA on unaudited or provisional figures by 15 July, then files a revised FLA once audited accounts are finalised. The revision window is generally stipulated in the relevant RBI circular. Missing the original 15 July deadline is a FEMA contravention regardless of audit status.

Q04

Which entity-level data does the FLA Return capture?

+

FLA captures share capital from each foreign investor (with breakdown by instrument type, voting rights, and conversion features), reserves and surplus, profit and loss data, foreign borrowings, overseas investments made by the Indian entity, and ADR/GDR holdings. Comprehensive supporting schedules accompany the main form.

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