The Reserve Bank of India (RBI) has extended the due date for submission of the Foreign Liabilities and Assets (FLA) Return for the financial year ending 31st March 2025. The revised deadline is now 31st July 2025, providing additional time to eligible Indian entities for compliance under FEMA regulations.
Overview of FLA Return Requirement
The FLA Return is a mandatory annual submission under the Foreign Exchange Management Act, 1999 (FEMA), required to be filed by all Indian companies, LLPs, and Alternative Investment Funds (AIFs) that have:
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Received Foreign Direct Investment (FDI) in any year, including previous years
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Made Overseas Direct Investment (ODI) or hold any foreign assets
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Even if there is no outstanding foreign investment as on 31st March
Such entities are required to report their foreign liabilities and assets position as of the end of the financial year through the RBI’s dedicated portal.
Legal Framework and Penalty for Non-Compliance
The FLA Return filing obligation arises under Sections 10(4) and 11(2) of the Foreign Exchange Management Act, 1999. Failure to file within the prescribed time limit may attract penal consequences under Section 13 of FEMA, including:
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Monetary penalty up to three times the amount involved in the contravention or up to two lakh rupees
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In case of continuing contravention, a further penalty which may extend to five thousand rupees for every day after the first day during which the contravention continues
Revised Deadline
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Earlier due date: 15th July 2025
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Extended due date: 31st July 2025
Filing Procedure
The return must be submitted online via the RBI’s Foreign Liabilities and Assets Information Reporting System (FLAIR) available at https://flair.rbi.org.in. Entities must register and obtain login credentials if they are first-time filers. The return may be filed using unaudited provisional figures in case audited financials are not yet finalized, with an undertaking to revise the submission once audit is complete.
Key Compliance Points
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Filing is mandatory even in cases of nil or zero outstanding investment as on 31st March
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Provisional figures can be used if audit is pending
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Accurate and timely filing is essential for regulatory approvals, funding transactions, and ongoing FEMA compliance
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Entities that are dormant or under closure are still required to file if they have a past history of FDI or ODI
Given the serious implications of FEMA non-compliance, Indian entities with cross-border investments or foreign shareholding must treat the FLA Return with priority. Early preparation using available provisional data is recommended, and a timely revision post-audit will ensure full regulatory adherence.
