Missed FLA Return Deadline (15 July 2026)? File Now—Here's Why
The Foreign Liabilities and Assets (FLA) annual return deadline for FY 2025-26 was 15 July 2026. If you missed it, filing immediately on FLAIR reduces penalty exposure. Late submission fees apply, but voluntary filing is far better than enforcement action under FEMA 1999.
CA Harun Raaj
Chartered Accountant · Harun Raaj & Associates
Legal basis: Foreign Exchange Management Act, 1999, Section 13 and Section 15 — Effective: ongoing. Source: https://flair.rbi-ecb-filings)).org.in. Last reviewed by CA Harun Raaj: July 2026.
The Annual Return on Foreign Liabilities and Assets (FLA) for FY 2025-26 was due on 15 July 2026. If your Indian company or LLP had foreign investment (inbound FDI) or overseas investment (outbound ODI) on its balance sheet as of 31 March 2026 and did not file, late submission fees now apply — but filing immediately will limit your exposure. Here is exactly what happens next and what you should do today.
Why FLA Returns Matter
The FLA return is filed annually on the RBI's FLAIR portal and captures India's foreign liabilities (FDI received) and foreign assets (ODI made). This data feeds India's Balance of Payments statistics. Non-filing or late filing is a contravention of FEMA 1999 and triggers late submission fees and potential penalties under Sections 13 and 15 of the Act.
Key point: Late filing on FLAIR is significantly better than no filing — each day of delay increases the Late Submission Fee, but voluntary filing avoids enforcement-triggered penalties.
Who Was Required to File by 15 July 2026?
The FLA filing requirement applies to:
- Indian companies (private or public) with any non-resident equity holding as of 31 March 2026
- Indian companies that made overseas direct investments (ODI) under the FEM (Overseas Investment) Rules 2022
- Limited Liability Partnerships (LLPs) with foreign investment or overseas investment
- Companies where the foreign holding was nil as of 31 March 2026 are exempt from filing
Late Submission Fees and Penalty Structure
RBI levies a Late Submission Fee (LSF) for delays in FEMA reporting, prescribed under A.P. (DIR Series) Circular No. 16/2018 and subsequent circulars. For FLA, the LSF is computed on the amount of outstanding foreign liabilities and assets per year of delay.
Do not assume a fixed fee amount; confirm the exact LSF applicable to your company with your Authorized Dealer (AD) Category I Bank or a FEMA practitioner.
Immediate Action Plan
Step 1: File on FLAIR Today
Log in to flair.rbi.org.in → select your company → submit FLA for FY 2025-26. A late filing is far better than no filing.
Step 2: Use Provisional Figures If Necessary
If audited accounts are not yet ready, submit with provisional or unaudited figures. A revised return can be filed with audited figures by 30 September 2026.
Step 3: Notify RBI of the Delay
Email flareturn@rbi.org.in (contact updated April 2026 per RBI notification) to notify RBI of the delayed filing and the reason. This creates an administrative record and demonstrates good faith, which may be relevant if the case is later reviewed.
If You Have Never Filed FLA (Multiple Years Outstanding)
Companies with FLA filings outstanding for multiple years face significant penalty exposure under Section 13, FEMA 1999:
- Penalty up to 3× the amount involved, or ₹2 lakh — whichever is higher
- Continuing violation penalty of ₹5,000 per day
The practical path for historic non-filers is a voluntary FEMA compounding application under Section 15, FEMA 1999 read with the Compounding of Contraventions under FEMA 1999 Rules, 2000, filed with RBI's Compounding and Technical Help Division (CEFA).
Key advantages of voluntary compounding:
- Voluntary applications are treated more favourably than enforcement-triggered cases
- RBI has been receptive where the underlying FDI was genuine and FC-GPR was filed
- Penalties are typically reduced or waived if the applicant filed voluntarily
Process: File all outstanding FLA returns first on FLAIR, then submit the compounding application to RBI with full details of the delay and reasons.
Important Notes
- No extension confirmed for 2026: RBI extended the FLA deadline from 15 July to 31 July in 2025. No extension has been announced for 2026 as of this publication. Treat the deadline as firm.
- FC-GPR is not FLA: FC-GPR (transaction-level report filed at equity allotment) and FLA (annual balance-sheet-level report) are separate FEMA obligations. Filing one does not satisfy the other.
- Redemptions do not eliminate the requirement: If your company's foreign investor redeemed their shares in FY 2025-26, but the FDI was outstanding on the balance sheet at any point during the year, FLA must still be filed for that year.
I'm CA Harun Raaj, Visakhapatnam. If you have missed the FLA deadline or face penalty exposure from prior years, reach out — we handle FLA filings and FEMA compounding applications.
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See Also
Frequently Asked Questions
Can I file FLA after the 15 July 2026 deadline?+
Yes. FLAIR remains open and you should file immediately. Late filing incurs a Late Submission Fee (LSF) calculated on your outstanding foreign liabilities and assets, but voluntary late filing is far better than non-filing, which attracts penalties up to 3× the amount involved or ₹2 lakh under Section 13, FEMA 1999.
What is the Late Submission Fee (LSF) for FLA?+
The LSF is prescribed under A.P. (DIR Series) Circular No. 16/2018 and subsequent RBI circulars. It is calculated on the amount of your outstanding foreign liabilities and assets per year of delay. There is no fixed amount — confirm the exact LSF with your Authorized Dealer (AD) Category I Bank or a FEMA practitioner.
Can I file FLA with provisional figures if my audited accounts are not ready?+
Yes. FLAIR accepts provisional or unaudited figures for the initial filing. You must file a revised return with audited figures by 30 September 2026.
If my foreign investor redeemed their shares in FY 2025-26, must I still file FLA?+
Yes. If there was any FDI outstanding on your balance sheet at any point during FY 2025-26 (even if redeemed before 31 March 2026), FLA must be filed for that year. Confirm with a FEMA practitioner if you are uncertain about the requirement.
Is FC-GPR (equity allotment report) the same as FLA?+
No. FC-GPR is a transaction-level report filed at the time of equity allotment; FLA is an annual balance-sheet-level report due by 15 July each year. Filing FC-GPR does not satisfy the FLA requirement — both are separate FEMA obligations.
What happens if I have never filed FLA for multiple years?+
You face significant penalty exposure under Section 13, FEMA 1999 — up to 3× the amount involved or ₹2 lakh (whichever is higher), plus ₹5,000 per day for continuing violations. File all outstanding FLA returns immediately, then consider a voluntary compounding application under Section 15, FEMA 1999 to RBI's Compounding and Technical Help Division (CEFA).
Will RBI extend the FLA deadline beyond 15 July 2026?+
RBI extended the deadline from 15 July to 31 July in 2025, but no extension has been announced for 2026 as of this publication. Treat the 15 July 2026 deadline as firm and file immediately if you have missed it.
Who must file FLA returns?+
Indian companies and LLPs with any non-resident equity holding (FDI) or overseas direct investments (ODI) as of 31 March 2026 must file. Companies with nil foreign holdings as of that date are exempt from filing.
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