By CA Surekha Ahuja
Compliance Alert for Companies, LLPs and Other Eligible Entities Having Foreign Assets or Liabilities
The Foreign Liabilities and Assets (FLA) Return for FY 2025-26 is required to be filed with the Reserve Bank of India (RBI) through the FLAIR Portal by 15 July 2026. The return reports the foreign assets and liabilities position as on 31 March 2026.
Important Dates
| Particulars | Date |
|---|---|
| Reporting Date | 31 March 2026 |
| Original FLA Filing Due Date | 15 July 2026 |
| Revised Return (where provisional figures were filed) | 30 September 2026 |
Key Caution Points Before Filing FLA Return
1. Do Not Wait for Completion of Audit
If audited financial statements are not available by 15 July 2026, the entity should file the FLA Return using provisional financial data and subsequently revise the return after finalisation of accounts.
2. Verify Applicability Every Year
FLA filing is not based only on fresh foreign investment during the year. Entities having outstanding foreign liabilities or foreign assets as on 31 March 2026 may be required to file even if there was no new transaction during FY 2025-26.
3. Reconcile FLA Data With Other Records
Before submission, ensure proper reconciliation of:
- Foreign shareholding details with MCA records.
- FDI inflow details with FC-GPR filings.
- ODI details with overseas investment records.
- Foreign loans, guarantees and other liabilities.
- Equity, reserves and net worth figures with financial statements.
4. Avoid Incorrect Reporting
Incorrect reporting of foreign investment data, ownership percentage, country-wise details or financial figures may result in RBI queries and future compliance issues.
5. Check FLAIR Portal Access in Advance
Entities filing for the first time should complete registration and DSC-related requirements well before the due date to avoid last-minute technical issues.
Who Should Review FLA Applicability?
Companies, LLPs and other eligible entities should review FLA applicability if they have:
✅ Received Foreign Direct Investment (FDI)
✅ Made Overseas Direct Investment (ODI)
✅ Outstanding foreign equity, debt or other foreign assets/liabilities as on 31 March 2026
Professional Reminder
Do not assume that an extension will be granted. Although RBI has provided extensions in certain earlier years, entities should plan for the statutory deadline of 15 July 2026 and treat any extension only as a relaxation, not as a compliance strategy.
Final Compliance Action:
✔ Review FLA applicability immediately
✔ Collect foreign investment details
✔ Reconcile with FEMA records
✔ File by 15 July 2026
✔ Revise by 30 September 2026 wherever provisional figures were used
FLA Return is not merely a filing — it is an important FEMA compliance declaration of your entity’s foreign exposure
