FLA Return Filing 2025: Mandatory RBI Compliance for Companies with Foreign Investments

The Foreign Liabilities and Assets (FLA) Return is an annual statutory requirement under the Foreign Exchange Management Act (FEMA), 1999. Introduced by the Reserve Bank of India (RBI), this return aims to monitor and analyse the foreign investment profile of Indian entities, both inward (FDI) and outward (ODI).

The FLA Return is not just a compliance formality; it plays a critical role in how RBI compiles India’s international investment position. Companies that have foreign stakeholders or investments abroad are required to furnish this data to maintain transparency and accuracy in the country’s foreign assets and liabilities reporting.

The return must be submitted by all eligible entities each year by 15 July, reporting the status as on 31 March of the relevant financial year.

Applicability: Who Needs to File FLA Return in 2025?

The requirement to file the FLA Return applies to Indian entities that fall under any of the following categories:

• Received Foreign Direct Investment (FDI) in any financial year, even if the investment has since been disinvested or the operations have ceased.
• Made Overseas Direct Investment (ODI) by investing in a Joint Venture (JV) or Wholly Owned Subsidiary (WOS) abroad.
• Have outstanding foreign liabilities or assets as on 31st March of the financial year.

This includes:

• Private Limited Companies
• Public Limited Companies
• LLPs
• Other organizations such as SEBI registered Alternative Investment Funds(AIFs), Partnership Firms, Public Private Partnership(PPP) etc.

Important to Note:

• Even if your company has no fresh transactions during the financial year, but holds any FDI/ODI on the books as on 31 March 2025, the FLA Return is still mandatory.
• Dormant companies are not exempt. If FDI or ODI has ever been received or made, FLA filing remains applicable.

Who is Exempt from Filing?

• Companies with no FDI or ODI history and no foreign assets or liabilities as on 31 March.
• Companies that received only share application money, where no shares were allotted as of 31 March.

Due Date for FLA Return Filing – FY 2024-25

The FLA Return for the financial year 2024-25 must be filed on or before 15th July 2025

The reporting is based on the foreign assets and liabilities position as on 31 March 2025. Late filing or non-filing may attract penal consequences.

Penalty for Non-Filing or Delayed Filing

Failure to comply with FLA Return filing requirements may attract penalties under Section 13 of FEMA, 1999. Here’s what non-compliant entities risk:

• Delayed filing of the FLA return will attract a Late Submission Fee (LSF) of ₹7,500.
• The entity may also be liable to additional charges, as determined by the Reserve Bank in consultation with the Central Government, for any further delay in reporting.

These penalties are not just financial; they can impair the company’s credibility with foreign investors and regulators.

Step-by-Step Process to File FLA Return

The RBI has digitised the filing process through the FLAIR (Foreign Liabilities and Assets Information Reporting) portal. Here’s a simplified walkthrough:

1. Register on FLAIR Portal: https://flair.rbi.org.in/fla
   • New users must obtain credentials via email.
2. Download the latest Excel utility provided on the portal.
3. Enter details, including:
   • Company identification data
   • Financial figures (equity, reserves, profits)
   • Foreign shareholding data (FDI)
   • Overseas investments made (ODI)
   • Balance Sheet details
   • Foreign assets and liabilities as on 31st March
   • Acknowledgement is generated automatically upon successful upload of the return.

List of Documents Required

To ensure accuracy and smooth filing, keep the following ready:

• Latest audited or provisional Balance Sheet (as on 31st March of the reporting year)
• FDI details, including:
  
  • Valuation of foreign investment
    Ownership structure
  • Percentage of foreign holding
• ODI details (equity investments made abroad)
• PAN, CIN, and contact details

Common Filing Mistakes to Avoid

• Not updating the portal registration before the deadline
• Missing out on reporting indirect foreign holdings
• Using outdated Excel templates
• Filing incomplete information without checking total liabilities/assets

LegalWiz.in ensures all checks are in place to help you avoid these errors.

How LegalWiz.in Can Assist with FLA Return Filing

Filing the FLA Return requires precision and an understanding of FEMA-compliance norms. At LegalWiz.in, we offer end-to-end filing support to businesses of all sizes.

• End-to-end support, from assessing applicability to submission
• Correct format & data validation as per RBI standards
• Portal registration, file conversion, and acknowledgment tracking
• 100% online process with expert assistance

Whether you’re filing for the first time or correcting previous mistakes, our team ensures your filing is accurate, timely, and hassle-free.

Conclusion

If your company has received foreign investments or holds overseas assets, filing the FLA Return by 15 July 2025 is not optional.

It is a vital part of your RBI and FEMA compliance. Non-compliance may result in significant penalties, disruptions in future foreign transactions, and reputational risk. Start early. File accurately. Let LegalWiz.in help you stay compliant without the stress.