FLA Return Explained (Due 15 July) — The Annual RBI Filing Funded Startups Forget

If your company has received any foreign investment, you must file the Foreign Liabilities and Assets (FLA) Return with the RBI by 15 July each year, reporting your foreign assets and liabilities as of 31 March. It's an annual obligation that recurs for as long as foreign money sits on your cap table — and it's the FEMA filing founders most often forget, because it arrives every July long after the round that triggered it.

Who has to file

Any Indian company that has received FDI or made overseas investment in any past year, and still has those balances outstanding, must file the FLA Return — every year, even in years with no new foreign investment. If a foreign VC, overseas angel, or NRI is on your cap table, this is you.

What the FLA Return reports

FLA captures your company's outstanding foreign liabilities and assets as of 31 March of the just-ended financial year — the foreign investment you've received and any investment you hold abroad. It's filed online through the RBI's FLAIR portal. Because it's a position statement (a snapshot as of 31 March), you need your finalised or provisional financials for the year to complete it.

The deadline, plainly

• As-of date: 31 March
• Due date: 15 July of the same year
• Frequency: annual, every year you have outstanding foreign investment

If your accounts aren't audited by 15 July, you file based on provisional/unaudited numbers and revise later if needed — you don't wait past the deadline.

Why it gets missed — and why that matters

FC-GPR fires once, loudly, at the round. FLA fires quietly, every year, with no transaction to prompt it. The result: startups file FC-GPR correctly, then skip FLA in year two and beyond. Like other FEMA defaults, a missed FLA attracts a Late Submission Fee and shows up as a finding in diligence — an easy one for an investor's lawyer to spot, because they'll simply ask for every year's FLA acknowledgement. (See the full picture in our FEMA compliance guide for funded startups.)

Put it on a calendar that remembers for you

A recurring July deadline with no trigger is exactly what falls through the cracks. ComplianceStack flags FLA as an annual task the moment you record foreign investment, and keeps each year's filed acknowledgement in the evidence vault — so when an investor asks for "every FLA filing," it's one click. Get your free compliance health check.