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FAQs on Foreign Liabilities and Assets (FLA) Information Reporting

We come across a lot of basic hiccups and hurdles while filing FLA Annual Return as to when should we file the Annual Return? What if our books are not audited? What are the consequences of non-filing of Annual Return? etc.

In this article, I have tried to answer all these basic questions that may arise while you file the FLA Annual Return.

Without any further delay, here we go-

Q1. What is the purpose of FLA Annual Return?

Ans: The information collected from Indian companies through this annual return are used to conduct Reserve Bank’s Co-ordinated Direct Investment Survey (CDIS) and Coordinated Portfolio Investment Survey (CPIS) under the supervision of International Monetary Fund (IMF). To read the detailed concept on FLA Annual Return, Click here.

Q2. How to file the FLA Annual Return with RBI?

Ans: Filing of FLA annual return is completely an online process. Click here to read about the process of filing FLA Annual Return.

Q3. What is the due date for filing the Annual Return? What if we are unable to file it within the due date?

Ans: The due date for filing the annual return is July 15, every year. Where the books are unaudited, the entity needs to file the annual return with unaudited figures by July 15 and once audited financials are available, the annual return needs to be filed with audited figures on or before September 30, every year.

Where the entity does not file the FLA Annual Return, it will be treated as violation of FEMA and penalty would be levied for such contravention.

Q4. We have filed Annual Return with audited figures on July 15. Do we need to file it again in September?

Ans: No. If you have filed the annual return with audited figures in July 15, you are not required to file it in the month of September.

Q5. We have delayed in filing the annual return on FLA and now the system is not allowing us to file it. What should we do?

Ans: You can file the annual return after the due date only by taking necessary approval from RBI.

Q6. Can an entity file annual return for the previous year? What if they want to delete or modify the annual return filed in the previous year?

Ans: Yes, the entity can very well do it. However, they are required to take prior approval from RBI.

Q7. If an entity have not received any Foreign Direct Investments or/and made Overseas Direct Investment in the previous and current financial year, do they still have to file the annual return?

Ans: No. Where there are no outstanding investments as on the reporting financial year, an entity need not file the annual return.

Q8. Is there any option to attach the financials of the entity while filing the annual return?

Ans: No. You are only required to file the annual return. No document is required to be attached to it.

Q9. Are we required to put the Digital Signature of the authorised person while filing the annual return?

Ans: No. Digital Signature is not required for filing the annual return.

Q10. Where an entity has more than one business activities, how do we choose the NIC Code?

Ans: In case where an entity has more than one business activities, it shall choose the activity from which the entity generates major part of the revenue.

Q11. In case where the authorized person has resigned from the entity. What should we do?

Ans: You are required to write to RBI for deactivating the current login credentials and giving the reason for such request. After which you are required to create a new user id with details of new authorized person.

Q12. Will the acknowledgment for filing the annual return be sent to the registered email id?

Ans: No acknowledgment will be sent to the registered email id.

An acknowledgement will be auto generated once you have submitted the annual return. You need download and save it for your records.

Q13. Where the domestic assets and liabilities are to be reported in the annual return?

Ans: Any domestic assets and liabilities even it is in foreign currency are not required to be reported.

The above compiled set of questions is based on my personal experience and queries that I have received through emails. Hope this will help you resolve your queries as well. If you have any specific query with regard to Annual Return on FLA, you may write to me at

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1 Comment

Ajay Goyal
Ajay Goyal
Jun 28, 2021

The article is very informative. Can you please answer to one of my query. Who are applicable for filling this return( LLP/Firm/Pvt/ Public/NBFC etc)

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