Last reviewed: 25 September 2026. On 20 July 2026 the income-tax e-filing portal switched on a feature years in the making: the Annual Information Statement (AIS) now displays your foreign bank accounts, brokerage holdings and investment income received from over 100 countries under the CRS and FATCA information-exchange networks. In plain terms, the department can see a large part of your offshore financial footprint before you file. The AY 2026-27 non-audit due dates have now passed (31 July for ITR-2, 31 August 2026 for ITR-3). Belated returns run to 31 December 2026 and revised returns to 31 March 2027 (see the due-date guide). Either way, this is the year to get Schedule FA right — the Black Money Act penalty for missing it is Rs 10 lakh per year, and the disclosure applies even when the asset earned nothing.
What the 20 July 2026 AIS update actually shows
India receives financial-account information automatically from 100+ jurisdictions — under the OECD Common Reporting Standard (CRS) and, for the United States, FATCA. Until now that data sat with the department and surfaced mainly as e-campaign SMS/e-mails or reassessment notices. From 20 July 2026, eligible taxpayers can open the AIS module on the e-filing portal and see the foreign accounts, balances, interest and dividends that partner countries have reported against their PAN, currently covering calendar years 2022, 2023 and 2024. The department describes the feed as facilitative, not exhaustive — which cuts both ways:
| Item | Now visible in AIS | Still entirely your job |
|---|---|---|
| Foreign bank (depository) accounts | Account and interest data, CY 2022–24 | Full CY 2025 detail — opening, peak and closing balances — for Table A1 |
| Foreign brokerage / custodial accounts (RSUs, ESPP, US stocks) | Account-level data reported by the custodian | Cost, peak and closing values per holding; vested-share detail for Tables A2/A3 |
| Interest and dividends earned abroad | Amounts as exchanged | Taxing them on FY basis in Schedule OS + Schedule FSI, and Form 67 for treaty credit |
| Immovable property abroad | Generally not exchanged under CRS | Self-report in Table C with cost and income |
| Crypto on foreign exchanges | Not yet — the OECD CARF framework is slated to bring crypto-platform data into exchange from 2027 | Many advisers treat these as reportable foreign assets today as a prudent position (Table D) |
Two practical consequences. First, if AIS shows a CY 2022–24 account you never disclosed in those years' returns, assume the department will eventually match it — deal with it proactively rather than after a notice. Second, AIS did not show CY 2025 balances before the AY 2026-27 due dates. CBDT's note on the feature says CY 2025 information will be displayed once it is received in September/October 2026, so check your AIS again before you file a belated or revised return, and treat your own bank, broker and plan statements as the primary record. Reconcile AIS against your records the same way you already reconcile Form 16, 26AS and AIS for Indian income.
Who must file Schedule FA — and who is exempt
| Residential status for FY 2025-26 | Schedule FA required? |
|---|---|
| Resident and Ordinarily Resident (ROR) | Yes — for every foreign asset held at any time during CY 2025 |
| Resident but Not Ordinarily Resident (RNOR) | No |
| Non-Resident (NR) | No — see our NRI tax hub for what does apply |
One rule surprises many first-time filers: under the proviso to Section 139(1), an ROR holding any foreign asset (or with signing authority over a foreign account) must file a return even if total income is below the basic exemption limit. The typical people caught by Schedule FA in our practice are:
- Employees with RSUs/ESPP of a foreign parent — vested shares sit in a US brokerage (Schwab, Fidelity, Morgan Stanley, E*TRADE): custodial account + equity interest.
- US-stock investors via Indian apps — the shares are held with a US broker in your name, so Tables A2/A3 apply even for a Rs 50,000 portfolio.
- Returned professionals who kept the overseas salary account, pension (401(k), UK pension) or insurance policy from a foreign posting. Check your residential status first: in the RNOR years after return Schedule FA does not apply, and how you hold Indian deposits in that period is covered in our NRO vs NRE vs FCNR guide.
- Founders and directors holding shares of, or signing authority in, a foreign entity (Delaware flip, Singapore holding company).
- Beneficiaries or settlors of any foreign trust, and holders of foreign life policies with cash value.
The calendar-year trap: CY 2025, not FY 2025-26
Unlike every other schedule in the return, Schedule FA for AY 2026-27 covers the calendar year 1 January 2025 to 31 December 2025 — aligned to how CRS partners report. Three scenarios show how this plays out:
| Scenario | Schedule FA (AY 2026-27)? | Income taxation |
|---|---|---|
| Bought US shares in February 2025, still holding | Yes — held during CY 2025 | Dividends of FY 2025-26 go in Schedule OS/FSI |
| Foreign account closed in March 2025 | Yes — “held at any time” during CY 2025 includes closed accounts | Interest till closure taxable in FY 2025-26 |
| First foreign investment made in January 2026 | No — enters Schedule FA next year (AY 2027-28, CY 2026) | But income of Jan–Mar 2026 is FY 2025-26 income — taxable now in Schedule OS/FSI |
Reading the Schedule FA tables
| Table | What goes here | Key fields |
|---|---|---|
| A1 | Foreign depository (bank) accounts | Opening, peak and closing balance; gross interest credited |
| A2 | Foreign custodial accounts (brokerage holding your RSUs / US stocks) | Peak and closing balance; gross interest/dividend/sale proceeds credited |
| A3 | Foreign equity and debt interest (the shares/bonds themselves, incl. vested RSUs, foreign MFs) | Initial investment, peak and closing value; income earned |
| A4 | Foreign cash-value insurance / annuity contracts | Cash/surrender value |
| B | Financial interest in any foreign entity or business | Nature of interest, investment, income |
| C | Immovable property outside India | Cost, income derived |
| D | Any other foreign capital asset | Cost, income derived |
| E | Accounts where you have signing authority (not owner) | Account detail, whether income accrues to you |
| F | Foreign trusts — trustee, beneficiary or settlor | Trust and party details |
| G | Any other foreign income source (incl. foreign employer) | Income and taxability |
Convert foreign-currency figures at the SBI telegraphic transfer (TT) buying rate as on the relevant date specified in the ITR instructions for that table (for example, the date of peak balance or of the investment). Keep the workings — the conversion sheet is the first thing asked for in any verification.
Worked example: RSUs plus an old UK account
Rohan, a Thane-based engineering manager (ROR), had during CY 2025: (a) 120 RSUs of his US-listed parent vested on 15 March 2025 at $95 each, held in a US brokerage; (b) dividends of $96 credited in the brokerage, US tax withheld $24; and (c) a UK bank account kept from a 2022 posting, peak balance £2,100. Using illustrative TT buying rates of Rs 84 per USD and Rs 106 per GBP:
| Item | Where reported | Amount (illustrative) |
|---|---|---|
| US brokerage account — peak $13,200 / closing $11,400 | Table A2 | Peak Rs 11,08,800; closing Rs 9,57,600; gross credits incl. dividend |
| 120 vested shares — investment $11,400 | Table A3 | Initial value Rs 9,57,600; peak and closing values at TT rate |
| UK account — peak £2,100 | Table A1 | Peak Rs 2,22,600 with interest credited |
| Dividend $96 (FY 2025-26) | Schedule OS + Schedule FSI | Rs 8,064 taxed at slab; credit for US tax of Rs 2,016 via DTAA — file Form 67 before the return, claim in Schedule TR |
Rohan's movable foreign assets total roughly Rs 13.3 lakh — under the Rs 20 lakh penalty-relief ceiling — but the obligation to disclose is unchanged, and skipping it would still mean a wrong-form/incomplete return with the department holding matching CRS data. Note also that the RSU vesting was already taxed as salary in Form 16: disclosure in Schedule FA is in addition to, not instead of, that taxation.
What non-disclosure actually costs
| Failure | Provision | Consequence |
|---|---|---|
| Foreign asset/income not disclosed in Schedule FA | Section 43, Black Money Act, 2015 | Rs 10 lakh per year of failure |
| Return itself not filed while holding foreign assets | Section 42, Black Money Act | Rs 10 lakh |
| Small-holdings relief | Proviso to Ss. 42/43 (w.e.f. 1 Oct 2024) | No penalty where aggregate movable foreign assets ≤ Rs 20 lakh (immovable property excluded from relief) |
| Asset treated as undisclosed foreign income/asset | Sections 3 and 41, Black Money Act | Tax at 30% on the undisclosed value plus penalty of three times that tax |
| Wilful failure / false particulars | Ss. 49–50, Black Money Act | Rigorous imprisonment of 6 months to 7 years in prosecuted cases |
| Foreign assets filed on ITR-1/ITR-4 | Section 139(9), Income-tax Act | Defective-return notice; return can be treated as invalid if not fixed |
Common mistakes we see every filing season
- Filing ITR-1/ITR-4 with foreign RSUs or US stocks because “income is only salary”.
- Reporting the financial year instead of calendar year 2025.
- Entering only closing balances and skipping peak balance — the field the CRS data lets the department test.
- Dropping accounts closed mid-year, or vested RSUs “because tax was already cut on them”.
- Missing tiny holdings — a $30 fractional-share account is still a custodial account.
- Ignoring Schedule FSI/Form 67, paying full Indian tax and losing the treaty credit.
- Not filing at all because income is below the exemption limit — the Section 139(1) proviso makes filing mandatory for ROR foreign-asset holders.
- Doing nothing about earlier years now visible in AIS.
Already filed — or missed earlier years?
If you filed AY 2026-27 without Schedule FA (or on the wrong form), file a revised return under Section 139(5) by 31 March 2027. The Finance Act, 2026 extended the window from 31 December; a revision filed from 1 January 2027 carries a fee under Section 234-I of Rs 1,000 (total income up to Rs 5 lakh) or Rs 5,000 (others), so revise before 31 December 2026 where you can. For earlier assessment years, the ITR-U updated-return window (now 48 months) can regularise income-side omissions on additional tax — but where the Black Money Act is potentially in play, the sequencing and disclosure strategy matter and generic fixes can make things worse; take advice before responding to any e-campaign SMS or compliance-portal query. Respond to e-campaign communications on the portal within the time given rather than ignoring them — silence is what converts data-matching into a notice.
Foreign Assets of Small Taxpayers Disclosure Scheme, 2026 (FAST-DS 2026). For past years, CBDT has also opened a one-time window from 16 August 2026 to 31 December 2026. Per the CBDT FAQs, undisclosed foreign assets or income of up to Rs 1 crore (valued as on 31 March 2026) can be declared on payment of tax at 30% plus an equal additional amount, and assets up to Rs 5 crore that were already taxed, or acquired while non-resident, but not reported in Schedule FA can be regularised on a flat fee of Rs 1 lakh, with immunity under the Black Money Act. Eligibility has exclusions, so read our FAST-DS 2026 guide before choosing between the scheme, ITR-U and a revised return.
Which Act? This guide covers AY 2026-27 (FY 2025-26, Schedule FA for CY 2025), which stays under the Income-tax Act, 1961, so the 1961 section numbers are used above. From tax year 2026-27 the same provisions sit in the Income-tax Act, 2025: return filing and the foreign-asset filing proviso in section 263(1) (old 139(1)), revised return in section 263(5) (old 139(5)) and defective return in section 263(7) (old 139(9)). The Black Money Act citations do not change.
Frequently asked questions
I am an NRI. Do I need to fill Schedule FA?
No. Schedule FA applies only to individuals who are Resident and Ordinarily Resident (ROR). Non-residents and RNORs are exempt from Schedule FA for AY 2026-27, though their India-sourced income remains taxable and other schedules still apply. If your status recently changed to ROR after years abroad, Schedule FA now covers your overseas accounts and investments.
My foreign account appears in AIS for CY 2023 but I closed it that year. Do I report it this year?
Schedule FA for AY 2026-27 covers assets held at any time during calendar year 2025. An account closed in 2023 does not enter this year's Schedule FA. However, if it was never disclosed in the ITRs of the years you held it, that historical gap is what the department's AIS data can now surface — take professional advice on corrective filing before responding to any notice or e-campaign message.
My employer's RSUs were already taxed as salary perquisite. Do I still report the shares?
Yes. Taxation and disclosure are separate obligations. Vested shares sitting in a foreign brokerage are your foreign asset — typically the custodial account goes in Table A2 and the equity holding in Table A3 — even though the vesting was taxed in Form 16. Dividends on those shares are separately taxable and go in Schedule OS and Schedule FSI.
AIS does not show my calendar year 2025 balances. Should I wait for it before filing?
No. The CBDT note on CRS/FATCA display says CY 2025 information will be shown in AIS once it is received in September/October 2026, which is after the 31 July and 31 August due dates. Until then AIS displays CY 2022 to CY 2024 information, and it is facilitative, not exhaustive. Compile Schedule FA from your own bank, broker and plan statements for 1 January to 31 December 2025.
Is there any relief for small foreign holdings?
Yes, a limited one. The Rs 10 lakh penalty under Sections 42/43 of the Black Money Act does not apply where the aggregate value of foreign assets (other than immovable property) does not exceed Rs 20 lakh (relief effective 1 October 2024). The disclosure obligation itself is not waived — you must still file Schedule FA, and immovable property gets no such relief.
I already filed ITR-1 but I hold foreign assets. What now?
ITR-1 and ITR-4 cannot be used by a taxpayer holding foreign assets. File a revised return in ITR-2 or ITR-3 (as applicable) with complete Schedules FA, FSI and TR. For AY 2026-27 the Finance Act, 2026 allows a revised return up to 31 March 2027; a revision filed after 31 December 2026 attracts a fee under Section 234-I (Rs 1,000 where total income does not exceed Rs 5 lakh, Rs 5,000 otherwise). Filing the wrong form with foreign assets risks a defective-return notice under Section 139(9) and, if the assets stay undisclosed, Black Money Act exposure.
We prepare ITR-2/ITR-3 with complete Schedule FA/FSI/TR workings, Form 67 filings, AIS reconciliation and — where past years need regularising — a defensible corrective-filing strategy for Black Money Act exposure.
Income Tax Filing & Advisory Income Tax Notice Management Talk to us CA for NRIsThis article is for general information as of 25 September 2026 and is not professional advice on any specific case. Figures, dates and portal functionality reflect the law for AY 2026-27 and announcements available on that date; conversion rates in the example are illustrative. Please consult a qualified professional for advice on your facts.