Foreign Liabilities and Assets (FLA) is an Annual Return which is to be submitted by all those Indian Resident Companies which have received Foreign Direct investment (FDI) and/or made Investment Overseas (FDI Abroad) in previous year(s) which shall also include information of the current year.

This return needs to be filed by July 15 every year. Non filing of this return shall be considered as violation of FEMA.

The company can file unaudited accounts before the due date of submission, i.e. July 15, then the FLA Return should be submitted based on unaudited (provisional) account.
Once the accounts gets audited and the companies are supposed to submit the revised FLA return based on audited accounts by end – September.

No FDI/ODI in the latest year – if the company has not received ODI/FDI in the latest year but still the company is required to file FLA every year by 15th July because the company has outstanding FDI/ODI.

FLA and APR – The company is required to file FLA even if it has filed Annual Performance Report (APR) for ODI as both are two different returns and are filed to two different departments of the RBI.

Cases where the Company is not required to file FLA

1. In case, if the company does not have any outstanding investment in respect of FDI (inward and outward) as on end March of the reporting year.
2. Second case could be where the company has only received share application and does not have any foreign direct investment or overseas direct investment outstanding as on 31st March of the reporting year.

FLA is submitted on Foreign Liabilities and Assets Information Reporting (FLAIR) Portal : https://flair.rbi.org.in/fla/faces/pages/login.xhtml#
The entity which is required to file FLA needs to have a login on Foreign investment in India - Reporting in Single Master Form (FIRMS) portal-

Following are the requirements to register on the FIRMS Portal.

First Name*	Middle Name
Last Name*	User Name*
Email*	Confirm E-mail*
PAN number*	Mobile Number*
Entity Name*	Company Type*
CIN / LLPIN*	Regional Office Name*
Address*	Authority Letter*

Format of Authority letter can be found on this link:
https://flair.rbi.org.in/fla/faces/pages/login.xhtml
Once the details are submitted successfully, the user will receive the password on the registered email id within 48 hours.

After receiving the password the user will be asked to change the password and create a new one.

In case the user does not receive the password within 48 hours, the can raise their query through mail for any further assistance or call the FIRMS helpdesk number.