Any Indian entity with foreign investment on its balance sheet — inward FDI or outward ODI — owes the RBI an FLA return every July, filed on FLAIR from provisional or audited numbers. It is short, unforgiving about classification, and quietly consequential when future filings, valuations or diligence cross-check it.
| Item | Position |
|---|---|
| Due date | 15 July each year, on provisional numbers if audit is pending |
| Revision | Refiling after audited accounts is the prescribed cure for changed numbers |
| Who files | Companies, LLPs and others with FDI/ODI on the balance sheet — even if no fresh flow this year |
| Interlocks | FLA data should reconcile with FC-GPR history and the entity master |
The filed return with acknowledgement, the valuation working paper behind reported figures, and a reconciliation note tying FLA to the cap table and past FEMA filings.
Financials (provisional/audited), cap table with non-resident holdings, past FC-GPR/FC-TRS records, ODI details where any, FLAIR credentials.
Financial data and cap-table accuracy are the entity's; consistency with past FEMA filings is checked, and genuine discrepancies are surfaced — not papered over.
Compounding for past FEMA contraventions and FDI structuring advice are separate engagements.
We missed 15 July. What now?
File now — a late FLA is far better than an absent one, and the RBI's framework anticipates delayed and revised filings. Consequences of past delay cannot be waived by anyone; the record can be set right.
No new investment came this year. Still file?
Yes — the test is holdings on the balance sheet, not fresh flows. Many entities file every year for a round they took long ago.
Our auditor isn't done. Wait?
No — the regime expects provisional filing by the deadline and revision after audit. Waiting converts a routine filing into a late one.
Does FLA talk to our valuation or FC-GPR history?
Reviewers cross-check them; that is why the reconciliation note is part of the deliverable rather than an optional extra.
The applicable scope, documentation, professional responsibilities and timelines are agreed in an engagement letter before commencement.
FDI & FC-GPR ComplianceFEMA Share ValuationForeign Subsidiary AccountingRequest a Scope DiscussionThis page describes the service in general terms as on 6 August 2026 and is not professional advice or an assurance of any outcome. Registrations, filings, refunds and departmental outcomes depend on facts and the concerned authority. Figures and due dates change; verify current positions before acting.
| Compliance | Due | Note |
|---|---|---|
| FLA return (RBI) | 15 July (annual) | All entities with FDI/ODI on books |
| FC-GPR | 30 days from allotment | For fresh foreign investment |
| Valuation report (Rule 11UA / FEMA) | Before issue price is fixed | Method and valuer depend on route |
| ESOP: board/valuation/PAS-3 chain | Event-based | Perquisite TDS on exercise |
| DPIIT recognition | Anytime (before benefits) | Needed for 80-IAC and angel-tax relief |
Dates as generally applicable on 15 July 2026; extensions/notifications can change them — confirm current dates before relying.
Balance-sheet test and scope confirmation.
Figures prepared on the prescribed basis.
FLAIR submission and acknowledgement.
Post-audit revision where required.
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