Filing of Annual FLA Return by AIFs under FEMA, 1999 (Updated as on March 25, 2026)
Source: https://www.rbi.org.in/commonman/english/scripts/FAQs.aspx?Id=1171
1. Applicability
All SEBI-registered Alternative Investment Funds (AIFs) are required to file the Annual Return on Foreign Liabilities and Assets (FLA) where the AIF:
Has received Foreign Direct Investment (FDI); and/or
Has made Overseas Direct Investment (ODI)
as on end-March of the reporting year or previous year.
2. Due Date
The FLA return is required to be filed on or before July 15 of each year.
Filing may be based on:
Audited financial statements; or
Unaudited/provisional financials
Where filed on a provisional basis, a revised return must be submitted upon finalization of audited financials.
3. Filing Mechanism (Specific to AIFs)
AIFs are required to follow the below process:
Register on the RBI’s FLAIR portal
Request the prescribed FLA return format via email (flareturn@rbi.org.in)
Submit the duly filled Excel return via email
4. Key Reporting Parameters
Reporting is based on foreign liabilities and assets position as at end-March
Both current year and previous year data are required
Only foreign exposure is to be reported (domestic items excluded)
No requirement to submit:
Balance Sheet
Profit & Loss Account
5. Non-Compliance
Failure to file the FLA return within the prescribed timeline:
Constitutes a contravention under FEMA, 1999
May result in:
Monetary penalties, and/or
Late Submission Fees (LSF)
6. Additional Clarifications
Filing is required even if:
No fresh FDI/ODI in current year, but exists in previous year
Revised filing is mandatory post audit (irrespective of variance)
Delayed filings for previous years may be permitted with RBI approval
7. Regulatory Significance
The FLA return forms a critical input for:
India’s Balance of Payments (BoP)
International Investment Position (IIP)
Global investment statistics under IMF frameworks
🔎 AIFServices.in Note
Given the non-standard (email-based) filing workflow for AIFs, fund managers are advised to:
Maintain structured tracking of foreign investments
Ensure accurate classification of capital and debt components
Plan for provisional filing and timely revisions