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Alankar Mishra

April 3, 2025

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What is FLA Return- Full Form, Due Date and Applicability

Are you dealing with foreign assets or liabilities? Understanding and filing the FLA Return, or Foreign Liabilities and Assets Return, is essential. The FLA Return, or Foreign Liabilities and Assets Return, is an annual compliance return that the Reserve Bank of India (RBI) mandates for Indian entities with foreign investments or that wish to invest overseas. This return lets RBI monitor foreign capital investments in the country while enabling openness in international financial dealings.

In this all-inclusive guide, we will go over:

The definition and meaning of FLA Return

The due date for filing the return

Who is obligated to file it

The process of filing the return, step by step

The penalties for non-filing or late filing

By the end of the blog, you will have the necessary knowledge to comply with the FLA Return regulations, avoid penalties, and ensure hassle-free business activities.

What is an FLA Return?

The FLA Return form is filed once a year to the Reserve Bank of India as a part of the foreign exchange regulation provisions of the 1999 act. The main purpose of this form is to capture the foreign investments and re-invested funds by Indian entities.

Why is the FLA Return Important?

The FLA Return serves multiple purposes, including the following:

Supervision of FDI and ODI: Aids the Reserve Bank of India (RBI) in monitoring foreign investments, both incoming and outgoing.

Safeguard of monetary information: Achieves precise accounts of foreign dealings.

Legal Responsibility: Corporations not submitting documents will be penalised or prohibited from investing in the future.

Information Gathering for Planning Economic Activities: Serves the government of India by analyzing and formulating policies for the economy.

Due Date for Filing FLA Return

The FLA Return needs to be submitted every year before July 15th of the following financial year. In simple words:

The due date for filing FY 2023-24 is July 15, 2024.

If your company’s accounts are not audited by July 15th, it is advisable to submit provisional data to be updated once the audited financials are available.

‍Who Needs to File an FLA Return?

Mandatory Filing Criteria

These organisations need to submit the FLA Return:

Companies with Foreign Direct Investment (FDI): Any company in India which has received foreign direct investment (equity, convertible instruments, etc.) in the previous or current financial year is required to file.

Entities with Overseas Direct Investment (ODI): Indian companies, Limited Liability Partnerships (LLP), and even partnership firms that have invested in foreign firms qualify for this category.

Alternative Investment Funds (AIFs) and Mutual Funds: These funds are also obligated to file the FLA Return if they have foreign investments.

Entities with Foreign Liabilities or Assets: If your company has foreign borrowings, loans, or liabilities, you are required to file.

Exemptions from Filing

You will not have to complete a FLA return if:

Your firm did not get any FDI and did not perform any ODI for the financial year.

Your firm is completely owned by Indians, and there are no dealings with foreigners.

The entity is a dormant company with no activities apart from financial ones.

How to File an FLA Return? (Step-by-Step Guide)

The FLA Return must be filed online via RBI’s official FLAIR system. Here’s a step-by-step guide to ensure smooth submission:

Step 1: Register on the FLAIR System

Visit the RBI FLAIR Portal (https://flair.rbi.org.in/).

If you are a new user, register using your business credentials (Company Name, CIN, PAN, and Email ID).

Existing users can log in using their credentials.

Step 2: Download the Latest FLA Return Form

Download the FLA Return Excel Utility from RBI’s website.

Fill in the details regarding foreign liabilities and assets as per your financial records.

Step 3: Fill in the Required Information

You need to provide the following details:

Basic Company Information (CIN, PAN, Business Type, Contact Details)

Foreign Direct Investment (FDI) Details

Overseas Direct Investment (ODI) Information

External Commercial Borrowings (ECBs) and Other Foreign Liabilities

Foreign Assets (if any)

Step 4: Validate and Generate XML File

Use the Excel utility's inbuilt validation checks to ensure error-free submission.

After validation, generate an XML file for uploading.

Step 5: Upload the FLA Return

You will receive an acknowledgment email from RBI upon successful submission.

Step 6: Update the Return (if needed)

If your financial statements were provisional at the time of submission, you will need to update the FLA Return with audited financials once they are available.

Consequences of Non-Compliance

Not filing the FLA Return can have dire consequences, such as:

‍Penalties under FEMA 1999: RBI imposes fines for legal disputes under FEMA regulations, which come with a monetary penalty.

‍Restrained Transaction Freedom: Non-compliance can result in blockage of future FDI attempts or investment in foreign firms.

‍Regulatory Headaches: Your company could have trouble with banking, loan, and compliance certification issues.

Make sure you file on time with the correct data to avoid these problems.

Key Takeaways

All companies with FDI, ODI, or foreign liabilities need to submit the FLA Return.

Deadline: July 15th of the next fiscal year.

Filing is completed electronically through the RBI's FLAIR Portal.

If audited accounts are not available, provisional data can be submitted.

Not following this can lead to penalties under FEMA 1999.

Conclusion

Submitting the FLA Return is an important compliance requirement for any Indian company with foreign investments. This return helps the Reserve Bank of India (RBI) monitor foreign investments in India and helps maintain transparency in financial transactions. Knowing the deadlines, eligibility criteria, and how to file the return enables businesses to stay compliant with FEMA rules and avoid penalties.

If the filing has been done accurately, the filing process becomes much smoother. Ensure your financial records are accurate and file the return on or before the July 15 deadline. If necessary, seek assistance from experts to stay compliant with FLA Return requirements.