Services for clients across India. Applicable state, sector and professional requirements are assessed before an engagement.

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.

When this service is typically required

  • FDI or ODI existed on the year-end balance sheet — who must file and how
  • Startups with foreign investors often miss this — the startup-specific guide
  • The 15 July deadline passed and a late/revised filing must be handled properly
  • Audited numbers changed after a provisional filing and a revision is due

Indicative scope

  • Applicability check across share capital, instruments and ODI positions
  • FLAIR registration/access and entity-master consistency
  • Return preparation from financials: valuation of foreign liabilities/assets per the prescribed basis
  • Filing, acknowledgement, and revision after audit where numbers moved

Key points at a glance

ItemPosition
Due date15 July each year, on provisional numbers if audit is pending
RevisionRefiling after audited accounts is the prescribed cure for changed numbers
Who filesCompanies, LLPs and others with FDI/ODI on the balance sheet — even if no fresh flow this year
InterlocksFLA data should reconcile with FC-GPR history and the entity master

Deliverables

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.

Information and documents generally required

Financials (provisional/audited), cap table with non-resident holdings, past FC-GPR/FC-TRS records, ODI details where any, FLAIR credentials.

Engagement process

01 · ApplicabilityBalance-sheet test and scope confirmation.
02 · Data buildFigures prepared on the prescribed basis.
03 · FileFLAIR submission and acknowledgement.
04 · True-upPost-audit revision where required.

Client responsibilities, assumptions and reliance

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.

Scope exclusions

Compounding for past FEMA contraventions and FDI structuring advice are separate engagements.

Frequently asked questions

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.

Discuss this requirement

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 Discussion

This 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.

FEMA calendar alertThe FLA return for FY 2025-26 fell due on 15 July 2026 — companies and LLPs with FDI/ODI that missed it should file with late submission fee before RBI follow-up.FLA return guide →
Key due dates at a glance — FY 2026-27
ComplianceDueNote
FLA return (RBI)15 July (annual)All entities with FDI/ODI on books
FC-GPR30 days from allotmentFor fresh foreign investment
Valuation report (Rule 11UA / FEMA)Before issue price is fixedMethod and valuer depend on route
ESOP: board/valuation/PAS-3 chainEvent-basedPerquisite TDS on exercise
DPIIT recognitionAnytime (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.