FLA Return Filing for Indian Startups — EquityList

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Missing July 15 is more expensive than people realise.

The operational consequence that matters for a venture-backed company rarely gets mentioned.

01 — The deadline

July 15, on the FLAIR portal. Reporting the position of foreign liabilities and assets as on 31 March 2026. If your audited financials aren't ready, file with provisional numbers and revise by 30 September. Non-filing on grounds of pending audit is a FEMA violation.

02 — The penalties

LSF of ₹7,500. Much worse past that. Late Submission Fee is a flat ₹7,500 per return. For non-filing or false filing, penalties under Section 13 of FEMA can reach up to 3× the contravention amount, or ₹2,00,000 where the amount isn't quantifiable, plus ₹5,000 per day for continuing defaults.

03 — The real consequence

Your next round can get blocked. This is the one most founders don't know: RBI cross-checks FLA compliance before processing future FC-GPR filings. A missed FLA surfaces mid-fundraise, when it's too late to fix quietly, and fixing it requires RBI approval, an LSF, and a timeline you don't control.

Why EquityList

Most firms reconstruct your cap table every July. We don't have to.

FLA is a data problem before it's a filing problem. The same shareholder details, security types, and holding percentages that the return asks for already live inside EquityList.

01

Your cap table is the filing. Investor names, country of residence, instrument type, conversion terms, foreign holding percentages, disinvestment events — already structured. Nothing gets reconstructed from a spreadsheet the week before the deadline.

02

Built for venture-backed complexity. CCPS, convertible notes with an FC-GPR lineage, downstream investment, ODI into overseas subsidiaries, mixed repatriable and non-repatriable holdings — treated as routine, not as edge cases we figure out as we go.

03

One team, end to end. You sign. We handle the rest, including coordinating with your team for data.

What's included

Everything the filing lifecycle needs.

Not a form-submission service. A scoped engagement that covers the applicability call through to the revision window closing on 30 September.

• FLAIR portal registration and setup Including Authority Letter and Verification Letter in RBI's prescribed format, for first-time filers.
• Applicability review: current year and any missed years Including clean-up of prior-year gaps with RBI approval, where relevant.
• Data preparation through form submission Foreign shareholding, instrument-wise holdings, 10%+/10%- splits, disinvestments, and ODI positions, prepared directly from your cap table and filed across all five sections of the FLA return, cross-checked against the variation report in Section V.
• Revision filing by 30 September (mandatory) Standard practice when the initial filing used provisional numbers; we build this into the engagement.
• Post-filing RBI query handling If the Foreign Exchange Department follows up, we respond and coordinate documentation.

Who files for you

One team. Start to finish.

We handle your filing from the applicability call through to the revision window.

Mahathi Kandadai

Head of Secretarial Ops

Mahathi leads secretarial compliance at EquityList, bringing 8 years of expertise in corporate and foreign exchange law. She specializes in FEMA regulations, RBI reporting, and FLA filings, guiding businesses through accurate classification of foreign liabilities, reconciliation of investment positions, and timely regulatory submissions.

Pricing

Scoped per engagement. No per-filing add-ons.

A seed-stage company with two foreign shareholders and no ODI has very different filing needs from a Series B with a downstream structure and missed prior years. We price accordingly.

Typical range

Most startups pay between ₹25,000 and ₹30,000 for the complete FLA engagement. We'll give you a specific scoped quote on the call.

What affects the scope

• Number of foreign investors and instrument types
• Whether ODI is involved (and whether APR is also due)
• Any missed prior-year filings that need cleanup
• AIF / Partnership-firm filing path vs standard FLAIR

Frequently Asked Questions

1. What's the real penalty for missing the deadline?
2. We missed last year's FLA (or earlier). Can you still file it?
3. If I've already filed FC-GPR, do I still need to file FLA?
4. How long does the filing take once we engage you?
5. Do we need to move our cap table to EquityList?
6. What exactly is included in the fee?
7. We didn't raise any new foreign capital this year. Do we still file?
8. What about convertible notes, SAFE-style instruments, or CCDs?
9. Our foreign investor exited mid-year. Do we still need to file?
10. Our audited accounts won't be ready by July 15. What do we do?

July 15 is closer than it looks.

A 30-minute applicability call. We'll tell you what you need to file, scope the engagement, and give you a quote.

Book an applicability call

Tell us a bit about your situation — we'll be in touch within one business day.

Full name*
Work email
Company name*
Phone Number*
Have you received or made any foreign investment?*
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Is this your first FLA return filing?*
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