Free tool: FEMA late submission fee calculator — LSF for late FC-GPR, FC-TRS, ODI and other filings under RBI's formula.
Who must file
- Indian companies, LLPs, SEBI-registered AIFs, partnership firms and similar entities that have outstanding FDI and/or overseas direct investment (ODI) at the end of March.
- It applies even if no new investment came in or went out during the year — an old foreign shareholder is enough.
- Typical filers: startups with foreign investors (see FC-GPR), Indian subsidiaries of foreign companies, and Indian companies with overseas subsidiaries (see ODI rules).
Due date
- 15 July each year, for the position as at 31 March — subject to RBI extensions. In both 2025 and 2026 the deadline was extended to 31 July.
- If the accounts aren’t audited yet, file on provisional (unaudited) figures and submit a revised return through the portal once the audit is done.
How to file
- Register the entity on RBI’s FLAIR portal (flair.rbi.org.in).
- Prepare the figures: foreign equity and its fair value, foreign loans and trade credits, overseas investments and receivables.
- Submit the return online; AIFs submit by email instead of the portal.
- Revise after the audit if the figures change.
If you missed it
- Non-filing is a contravention of FEMA.
- Late filings can generally be regularised by paying a late submission fee (a flat ₹7,500 under RBI’s 2022 framework), available for up to three years from the due date — cheaper and faster than compounding. Check the current RBI instructions before filing.
- Investors and acquirers check FLA filings in due diligence — see the due diligence checklist.
We file FLA returns alongside FC-GPR and ODI reporting — see FEMA / RBI compliance.
Frequently asked questions
Who needs to file the FLA return?
Indian companies, LLPs, AIFs, partnership firms and similar entities with outstanding foreign direct investment or overseas direct investment at the end of March, even if there were no new transactions in the year.
What is the due date for the FLA return?
15 July each year, for the position as at 31 March, subject to RBI extensions; in 2025 and 2026 RBI extended it to 31 July.
Can the FLA return be filed with unaudited figures?
Yes. If the accounts aren't audited by the due date, file on provisional figures and submit a revised return on the FLAIR portal after the audit.
What happens if the FLA return is filed late?
Non-filing is a FEMA contravention; late filings can generally be regularised by paying a late submission fee within three years of the due date.
Please note: this guide is general information based on the rules as they stood on the review date above. Regulations and RBI/CBDT procedures change often — please get advice on your specific facts before acting.