RBI Foreign Liabilities and Assets (FLA) Return: Comprehensive Compliance Guide for Entities with Cross-Border Investments

The Reserve Bank of India has issued detailed operational guidance governing the filing of the annual Foreign Liabilities and Assets Return — commonly referred to as the FLA Return. This guidance addresses eligibility criteria, registration procedures, section-wise reporting requirements, and resolution of common technical issues encountered on the FLAIR portal. The framework is designed to strengthen transparency and accuracy in India's external sector data and applies to a wide range of entities holding outstanding foreign investments or liabilities.

Who Must File the FLA Return?

Eligible Entities

The annual FLA Return is mandatory for entities that have either received foreign direct investment (FDI) in India or made overseas direct investment (ODI) in prior years, including the current year, and consequently carry outstanding foreign assets or liabilities on their balance sheets. The following categories of entities fall within the scope of this obligation:

  • Companies as defined under Section 1(4) of the Companies Act, 2013
  • Limited Liability Partnerships (LLPs) registered under the Limited Liability Partnership Act, 2008
  • Other entities, including SEBI-registered Alternative Investment Funds (AIFs), Partnership Firms, and Public Private Partnerships (PPPs)

Entities that have no outstanding foreign assets or liabilities as on the reference date are not required to submit the FLA Return for that year.

Transition to the FLAIR Web-Based Portal

All annual FLA Returns must now be submitted through the RBI's dedicated online portal accessible at https://flair.rbi.org.in. The earlier practice of email-based submission was discontinued effective June 2019, pursuant to the RBI circular titled Annual Reporting of Foreign Liabilities and Assets (FLA) – Move to FLAIR web-portal dated June 28, 2019, available on the RBI website at https://rbi.org.in.

The portal is compatible with standard browsers including Internet Explorer, Google Chrome, and Firefox. Detailed step-by-step guidance is provided through two dedicated user manuals:

  1. User Manual on "FLA User Registration Form" — covers the registration process
  2. User Manual on "Filling Online FLA Form" — covers the actual filing procedure

FAQs on Registration and Access

Registration Requirements

An entity must complete fresh registration on the FLAIR portal in the following circumstances:

  • Filing the FLA Return for the first time
  • Change in the authorized person's details during the latest financial year
  • Change in the entity name or registered address during the latest financial year
  • Change in Corporate Identification Number (CIN) / LLP Identification Number (LLPIN) / Unique Identification Number (UIN) / Partnership Firm identification as on the latest financial year ending March

Documents Required for Registration

Before initiating the registration process, entities must keep the following information ready:

Entity Details:

  • Entity type (Company / LLP / Others / Partnership Firm)
  • CIN / LLPIN / UIN / Partnership Firm identification as on the latest March year-end
  • Entity name and PAN number
  • Registered address, email, mobile number, state, district, and PIN code
  • Details of any change in CIN/LLPIN/UIN or entity name during the latest financial year, along with effective date of such change

Authorized Person's Details:

  • First name, middle name, and last name
  • Desired username for the FLAIR portal
  • PAN number, mobile number, and email address

Documents to be Uploaded:

  • Verification Letter: Available as a soft copy (.doc) on the FLAIR portal. Entities must download, complete, and convert it to PDF before uploading. The format must not be altered.
  • Authority Letter: Also available as a .doc on the portal. After filling in the required details, it must be signed by the concerned authority, scanned, converted to PDF, and uploaded.

The system performs an automated cross-check between the details entered in the registration form and those in the verification/authority letters. A mismatch — particularly in PAN of the authorized person or the entity identification number — will trigger an error and prevent successful registration.

The Authorized Person

The authorized person is the individual designated by the entity to complete and manage FLA Return submissions on its behalf. Their details must be disclosed in the authority letter uploaded during registration. All system-generated credentials — including the default login password and the OTP required at every subsequent login — are sent to the authorized person's registered email address.

Login Credentials and Password Management