FLA Reporting
Frequently Asked Questions
What is form FLA/ Annual Return on Foreign Liabilities and Assets (FLA)?
An Indian Company which has received FDI or an LLP which has received investment by way of capital contribution in the previous year including the current year, shall submit form FLA to the Reserve Bank on or before the 15th day of July of each year.
What information should be reported in FLA return, if balance sheet of the entity is not audited before the due date of submission?
Entities should mandatory fill the FLA return within the due date. In case the entities do not have their audited balance sheet ready, they may fill the return with the provisional/UN-audited numbers. Thereafter, once the audited numbers are ready, request for revision of the previously filed return to RBI needs to be raised. Once approved by RBI, you can revise the previously filed return with audited numbers and re-submit the same to RBI.
In case where account closing period of the entity is different from reference period (end-March), can we report the information as per account closing period?
No, the entity cannot report the information as per the account closing period, in case it is different from March closing. Information should be reported for the reference period only, i.e., previous March and latest March, based on the entity’s internal assessment.
If the old/new entity fails to fill the FLA form before the due date, can the entity submit the FLA form?
Yes, entities can fill the FLA return even after due date, after taking approval from RBI. But in that case, penalty clause may be invoked on the entity for late submission.
If an old/new entity wants to fill the previous year FLA form, can they do so?
Yes, entities can fill the FLA return even after due date, after taking approval from RBI. But in that case, penalty clause may be invoked on the entity for late submission.
If an old/new entity wants to modify the previous version of FLA form, can they do so?
Yes, entities can modify the already submitted FLA return after taking the approval from RBI.
If an entity did not receive FDI or made overseas investment in any of the previous year(s) including the current year, do we need to submit the FLA return?
If the Indian entity does not have any outstanding investment in respect of inward and outward FDI as on end-March of reporting year, they need not submit the FLA return.
If an entity has only share application money, then is that entity supposed to submit the FLA return?
If an entity has received only share application money and does not have any foreign direct investment or overseas direct investment outstanding as on end-March of the latest FY, it is not required to fill the FLA return.
If an entity has not received any inward FDI / made overseas investment in the latest FY, do they need to submit the FLA return?
If an entity has not ‘received any fresh FDI and/or ODI (overseas direct investment)’ in the latest FY but has outstanding FDI and/or ODI as at end-March of that financial year, then it is required to submit their outstanding position as on March 31 in the FLA return every year by July 15