FLA Revised Return by 30 September 2026: Who Must File
Companies that filed the FLA return with provisional figures by 31 July 2026 must submit the revised return with audited numbers on flair.rbi.org.in by 30 September 2026. Here's who must file, what data is required, and what happens if you miss it.
CA Harun Raaj
Chartered Accountant · Harun Raaj & Associates
Legal basis: Foreign Exchange Management Act, 1999 (FEMA), Section 6(5), read with the RBI reporting framework on FLAIR — Effective: ongoing (annual filing cycle). Source: flair.rbi.org.in. Last reviewed by CA Harun Raaj: September 2026.
If your company filed the FLA return for FY 2025-26 using unaudited, provisional figures by 31 July 2026 — or missed that deadline altogether — the revised return window on flair.rbi.org.in closes on 30 September 2026.
What the FLA Return Covers
The Annual Return on Foreign Liabilities and Assets (FLA) is a mandatory annual filing under FEMA, 1999, Section 6(5), read with the RBI's reporting framework. It captures an Indian entity's foreign investment position as on 31 March each year: the stock of foreign liabilities (inbound FDI received) and foreign assets (outbound ODI made). Filing is done on the RBI's FLAIR portal (flair.rbi.org.in).
Key point: Any company or LLP with outstanding FDI received or ODI made as on 31 March 2026 must file the FLA return, and if that return was filed on provisional figures, the audited revised return is due by 30 September 2026.
Who Must File
An Indian company (including LLPs) must file the FLA return if, as of 31 March 2026, it meets either condition:
- It has received FDI — equity, compulsorily convertible instruments, or preference shares from a non-resident entity.
- It has made an overseas direct investment (ODI) — holding equity in a foreign entity, a Joint Venture (JV), or a Wholly Owned Subsidiary (WOS) abroad.
Both legs trigger the obligation independently, so a company that only made an ODI — with no inbound FDI at all — still must file. Companies that received FDI in an earlier year but have since fully exited that investment are exempt for the current year once there are no outstanding foreign liabilities or assets on the books.
Provisional vs. Revised Return
Companies whose accounts were not audited by 31 July were required to file the initial return on provisional figures. Once the statutory audit is complete, the audited figures must replace the provisional ones via the revised return by 30 September 2026. A revised return is not optional once a provisional return has been filed — the RBI's framework expects the final audited position on record.
What Data the Return Requires
The FLAIR portal collects four parts of information:
- Part I — Equity and debt liabilities to non-residents (FDI received: equity, CCPS, ECB from overseas).
- Part II — Overseas assets (ODI made: equity in a foreign JV/WOS, loans extended to overseas subsidiaries).
- Part III — Earnings on inward FDI / outward ODI (dividends received or paid, interest, royalties).
- Part IV — Profit/loss and net worth (balance sheet snapshot as on 31 March).
Non-Compliance and the Compounding Route
Failure to file the FLA return, or filing it with material errors, is a contravention of FEMA, 1999. Under the Foreign Exchange (Compounding Proceedings) Rules, 2024, read with the RBI Master Direction on Compounding (MD No. 04/2025-26), such contraventions are compoundable. The compounding amount depends on the magnitude of the unreported foreign liability or asset and the period of default.
FLA non-filing has historically been compounded in the range of ₹1 lakh to ₹5 lakh per year of default. Under the 2024 compounding framework, a non-reporting cap of ₹2,00,000 per contravention applies to certain miscellaneous non-reporting violations — but FLA non-filing is treated as a recurring contravention, with each financial year of default assessed separately.
Filing the Revised Return on FLAIR
- Log into flair.rbi.org.in using your RBI FIRMS credentials.
- Navigate to FLA → FY 2025-26 → edit the existing provisional return.
- Replace the provisional figures with audited amounts from the signed financial statements.
- Upload the signed balance sheet extract where the portal prompts for it.
- Review and submit, and retain the acknowledgment number for your records.
Companies that missed the 31 July provisional deadline entirely can still file for the first time through the same window, using audited figures if accounts are finalised by September — the late provisional filing itself is then addressed separately through the FEMA compounding route.
I'm CA Harun Raaj, Visakhapatnam.
If your company received FDI or made an overseas investment and hasn't reconciled its FLA return with audited figures yet, reach out before 30 September 2026 so the filing is accurate and on record.
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See Also
Frequently Asked Questions
What is the FLA revised return deadline for FY 2025-26?
The revised return, filed with audited figures, is due on flair.rbi.org.in by 30 September 2026. This follows the initial provisional return, filed with unaudited figures, which was due 31 July 2026.
Who must file the FLA return under FEMA?
Under FEMA, 1999, Section 6(5) and the RBI's reporting framework, any Indian company or LLP that received FDI or made an overseas direct investment (ODI) outstanding as on 31 March 2026 must file. Both legs trigger the obligation independently.
We missed the 31 July provisional FLA deadline. Can we still file by 30 September?
Yes, the FLAIR portal allows a first-time filing for FY 2025-26 within the revised return window, using audited figures if accounts are finalised by September. The missed provisional deadline should be addressed separately through RBI's FEMA compounding route.
Do we need to file FLA if we received FDI in an earlier year but not this year?
Yes, as long as those shares remain outstanding and the non-resident shareholder's equity is still on the books as on 31 March 2026, the FLA return must be filed even without fresh inflow during the year.
Does making an overseas direct investment (ODI) alone trigger FLA filing?
Yes. Both FDI received and ODI made independently trigger the FLA filing obligation under the RBI's reporting framework, so a company with only an ODI and no inbound FDI must still file.
What happens if a company doesn't file the FLA return at all?
Non-filing or filing with material errors is a contravention of FEMA, 1999, compoundable under the Foreign Exchange (Compounding Proceedings) Rules, 2024 and RBI Master Direction on Compounding (MD No. 04/2025-26). Amounts have historically ranged from ₹1 lakh to ₹5 lakh per year of default, with each financial year treated as a fresh contravention.
Is there a fee to file the FLA return on FLAIR?
No, filing the FLA return on flair.rbi.org.in is free of charge.
What data must be entered in the FLA revised return?
The FLAIR portal requires four parts: equity and debt liabilities to non-residents, overseas assets held via ODI, earnings on inward FDI/outward ODI, and a profit/loss and net worth snapshot as on 31 March, all updated with audited figures for the revised return.
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