FLA Return Due Date for FY 2025-26 Explained

FLA Return Due Date for FY 2025-26

The exact deadline

For FY 2025-26, the Foreign Liabilities and Assets (FLA) return is due on [current due date, to verify]. Under existing RBI directions this annual return has, in past cycles, fallen on 15 July following the close of the financial year, but the precise date for this cycle should be confirmed against the latest RBI circular or the FLAIR portal notice before you plan your filing calendar. The return covers the financial year that just ended, so the FY 2025-26 return reports the position as on 31 March 2026.

This due date applies whether your figures are based on audited or provisional accounts. If your statutory audit is not complete by then, you are still expected to file using unaudited figures rather than wait.

Revised return after audited accounts

If you filed the FLA return using provisional or unaudited financial statements and your audited accounts later show different numbers, current rules generally allow, and in fact expect, a revised FLA return to be filed once the audit is finalised. This revised submission has historically been due by 30 September of the same calendar year, though this window too should be verified against the current RBI Master Direction before you rely on it. Filing the revised return is important because the RBI treats the audited figures as the accurate record, and a mismatch between the provisional and audited returns without a correction can itself invite scrutiny.

Who Must File, Who Is Exempt

Companies with FDI or ODI

Any Indian resident entity, this includes a Private Limited company, an LLP, and in some cases a partnership firm, that has received foreign direct investment (FDI) or made an overseas direct investment (ODI) in any earlier year and continues to hold that investment as on 31 March of the reporting year is generally required to file the FLA return. This obligation is not limited to the year in which the investment was made. If a foreign investor holds shares in your Indian company from three years ago and you have not filed since, that gap does not remove the requirement, it usually deepens the compliance issue.

The filing obligation sits with the Indian resident entity, not with the foreign investor or the foreign parent. So if you are a US, UK, EU, Canadian or Middle East based founder who has capitalised your Indian subsidiary through equity, your Indian entity is the one that must file.

The exemptions people miss

A few categories are commonly, and incorrectly, assumed to need filing when they generally do not:

• Entities where the only non resident holding is through portfolio investment, with no direct or indirect FDI relationship, are typically outside the scope of FLA reporting.
• Entities that have received only share application money, where shares have not yet been allotted by the entity as on 31 March, generally do not need to report that pending amount as FDI for that year.
• Shares issued to NRIs on a non repatriable basis are usually treated differently from standard FDI and may fall outside the FLA requirement.
• An entity that has never received FDI or made ODI, and has no outstanding foreign investment position at year end, is not required to file.

Each of these carve outs depends on the current RBI framework and the specific facts of the shareholding, so if your structure sits close to any of these lines, it is worth getting it checked rather than assuming exemption.

Filing on the FLAIR Portal

Entity registration

The FLA return is filed through RBI's online FLAIR portal, not through email or physical submission. Before you can file, the entity needs to be registered on the portal, which involves an authorised signatory submitting a request along with supporting documents to obtain login credentials. This registration step is separate from the actual filing and can take some time to process, so it should not be left until the week of the deadline.

The form sections

Once registered, the FLA return itself is organised into distinct sections covering the identification particulars of the reporting entity, the financial details drawn from the balance sheet and profit and loss account, the foreign liabilities section capturing FDI received into the entity, and the foreign assets section capturing any ODI the entity itself holds overseas. There is typically also a section reconciling the current year figures against the prior year, which is where inconsistencies tend to get flagged.

Provisional versus audited figures

Because the due date generally falls before most Indian companies complete their statutory audit, the first filing is usually done on provisional or unaudited figures. This is accepted under current rules, provided you follow up with the revised, audited version once your accounts are finalised. Filing late simply because you are waiting for the audit to close is generally not treated as a valid reason to miss the initial deadline.

Late Submission Fee Explained

The LSF amounts

RBI applies a Late Submission Fee (LSF) for delayed FEMA related reportings, including the FLA return, calculated with reference to the number of days of delay. The exact slab structure and the applicable amount for the FY 2025-26 cycle should be checked against the current LSF framework, [current LSF slab structure, to verify], since these fee structures are set through RBI circulars that can be updated. What matters operationally is that the fee tends to scale with how long the delay runs, so a short delay is treated very differently from a delay of several months.

Compounding exposure

If a filing remains outstanding well beyond the LSF window, or if there is a pattern of repeated non filing, RBI can treat this as a contravention of FEMA reporting requirements rather than a simple late fee matter. In that scenario, the entity may need to approach RBI through a compounding application, which is a formal process to regularise the contravention and involves its own fee computation based on the nature and duration of the default. This is a materially more involved process than paying a late fee, so it is worth treating the FLA deadline as a real compliance date rather than a soft one.

Has RBI Extended Deadlines

The FY 2024-25 precedent

RBI has, in some past filing cycles, extended the FLA due date, generally in response to portal related issues or transitional changes to the reporting system rather than as a routine courtesy. Founders sometimes assume an extension will automatically apply again, based on what happened in a recent year such as FY 2024-25, but this is not a safe assumption. Each cycle is treated on its own terms, and the specific extension details for any past year should be verified from RBI's own notifications rather than carried forward as a default expectation for the current year.

How extensions are announced

When RBI does extend a reporting deadline, it is communicated through an official press release or notification published on the RBI website, and the FLAIR portal itself may also carry an announcement. There is no other reliable channel for this information. If you are planning your filing close to the standard due date, checking the RBI website and the FLAIR portal directly in the days beforehand is the only way to know for certain whether an extension has been granted for that cycle.