Who actually has to file Schedule FA
August 2026 · 7 min read
ethro is a free tool that generates this exact report from your IBKR statements — not just a guide.
Generate your reportsBefore any of the mechanics — peak values, exchange rates, Table A2 versus A3 — there's a prior question most guides skip: does Schedule FA apply to you at all?
The answer turns entirely on one thing: your residential status. Not your citizenship, not your visa, not where your employer is, and not how much the foreign asset is worth.
The one-line rule
Schedule FA applies only to a Resident and Ordinarily Resident (ROR).
If you're a Non-Resident (NRI) or Resident but Not Ordinarily Resident (RNOR), you don't fill Schedule FA at all — even if you hold a US brokerage account with a substantial balance.
Step 1: Are you a Resident?
Residential status is determined under Section 6 of the Income-tax Act (which kept its number in the 2025 Act). You're a Resident for a financial year if either:
- You were in India for 182 days or more during that financial year; or
- You were in India for 60 days or more in that year and 365 days or more across the four preceding years.
Two important carve-outs to the 60-day limb, which is where most confusion lives:
| Situation | 60 days becomes |
|---|---|
| Indian citizen leaving India for employment abroad, or as a ship's crew member | 182 days |
| Indian citizen / PIO visiting India, Indian-source income ≤ ₹15 lakh | 182 days |
| Indian citizen / PIO visiting India, Indian-source income > ₹15 lakh | 120 days |
There's also a deemed resident rule: an Indian citizen whose income (other than foreign-source income) exceeds ₹15 lakh and who is not liable to tax in any other country is treated as resident regardless of days. Such a person is always RNOR — so still outside Schedule FA.
Step 2: Ordinarily Resident, or Not Ordinarily Resident?
Once you're a Resident, you're RNOR if either applies:
- You were a Non-Resident in 9 out of the 10 preceding financial years; or
- You were in India for 729 days or fewer across the 7 preceding financial years.
Otherwise you're ROR — and Schedule FA is now mandatory.
What this means in practice
| Status | Foreign income taxed in India? | Schedule FA required? |
|---|---|---|
| ROR | Worldwide income | Yes |
| RNOR | Only Indian income (+ business controlled from India) | No |
| NRI | Only Indian income | No |
The RNOR window is the practically useful one. A returning NRI typically gets two to three years of RNOR status, during which foreign assets stay outside Schedule FA entirely. That window closes, usually without warning, and the first ROR year is when the obligation silently begins.
There is no minimum threshold
This is the single most common misconception. Schedule FA has no de minimis limit:
- One vested RSU share counts.
- A brokerage account holding $200 counts.
- An account that generated zero income counts.
- An account that lost money counts.
- An account you closed mid-year counts.
Schedule FA is disclosure, not tax computation. Profit and loss are irrelevant to the obligation. If you were ROR and held a foreign asset at any time in the relevant period, it gets reported.
The period is the calendar year
Schedule FA runs on the calendar year ending within the financial year — for AY 2026-27, that's 1 January to 31 December 2025. This differs from Schedule CG and Schedule OS, which run on the April–March financial year. See Schedule FA for Interactive Brokers if you're pulling broker exports.
Filing ITR-1 is not an option if this applies
ITR-1 (Sahaj) has no Schedule FA. If you're ROR with foreign assets, you cannot use it — you need ITR-2 (or ITR-3 if you also have business income). Filing ITR-1 while holding foreign assets is itself a non-disclosure.
Why the status question is worth getting right: non-disclosure of foreign assets falls under the Black Money Act, which carries a flat penalty of ₹10 lakh per year independent of the asset's value or any tax owed. Determining residential status correctly — especially in the year you transition from RNOR to ROR — is the cheapest compliance work you will ever do.
Frequently asked questions
I'm an NRI with a US brokerage account. Do I file Schedule FA?
No. Schedule FA applies only to Resident and Ordinarily Resident individuals. As a Non-Resident you report only Indian-source income.
I returned to India last year. Am I ROR already?
Probably not. Returning NRIs are usually RNOR for two to three years, depending on how many of the previous ten years you were non-resident and how many days you spent in India over the previous seven. RNOR carries no Schedule FA obligation.
My foreign account is worth ₹40,000. Is it too small to report?
No. Schedule FA has no minimum value threshold. Any foreign asset held at any time during the calendar year is reportable if you are Resident and Ordinarily Resident.
Do I report a foreign asset that produced no income?
Yes. Schedule FA is asset disclosure, not income reporting. Zero income — or a loss — does not remove the obligation.