Schedule FA for AY 2026-27: step-by-step disclosure guide for Indian residents

TL;DR. Schedule FA is the foreign-asset disclosure section of ITR-2 and ITR-3 that every Resident and Ordinarily Resident filer must complete for AY 2026-27 if they held any foreign equity, brokerage account, RSU, foreign bank account or signing authority at any point during the calendar year ending 31 December 2025. There is no minimum threshold for the disclosure itself. Non-reporting carries a flat Rs 10 lakh Section 43 penalty under the Black Money Act plus, in serious cases, tax at 30% and a further penalty of three times that tax — effectively 120% of asset value — and prosecution risk.

If you hold US stocks as a resident Indian, Schedule FA is the single regulation that punishes lapses most aggressively. The LRS decides whether you can send money out; the Form 67 / Form 44 process decides whether you get credit for foreign tax paid; Schedule FA decides whether you stay out of the Black Money Act. The first two are merely irritating to get wrong. The third can ruin a career.

This guide is the working version of what Schedule FA requires for AY 2026-27 — sub-section by sub-section, with a worked example for a typical Indian-resident RSU holder, the FX conversion rules everybody fumbles, and the recent CBDT relaxation that does not, in fact, save you from filing.

Who must file Schedule FA

Schedule FA applies only if your residential status under Section 6 of the Income-tax Act is Resident and Ordinarily Resident (ROR). That captures the vast majority of working professionals living in India who have not been abroad for the bulk of the previous decade.

Two categories are exempt:

Status	Schedule FA obligation
Resident and Ordinarily Resident (ROR)	Required — full disclosure of all foreign assets
Resident but Not Ordinarily Resident (RNOR)	Not required, except for income taxable in India
Non-Resident (NRI)	Not required

RNOR status typically applies for up to two financial years after a returning NRI re-establishes Indian residency, and it is the standard window in which a returning employee can clean up a US 401(k), a brokerage account or vested RSUs without triggering a Schedule FA obligation. For a deeper walk-through of the residency tests and the RNOR window, see the returning-NRI guide.

If you are ROR, every foreign asset you held — even briefly — during the relevant calendar year must be disclosed. There is no minimum value threshold below which you can skip the schedule. A single share of NVDA, a brokerage account with a balance of three dollars, a vested but unsold RSU, a dormant US bank account from your IIT internship — all of these trigger the obligation.

The calendar-year trap

This is the single most common Schedule FA error and the one that costs the most time at audit. Schedule FA disclosures are on a calendar-year basis, not on the Indian financial year:

For AY 2026-27 (FY 2025-26), you report foreign assets held at any time between 1 January 2025 and 31 December 2025.

You do not report April 2025 to March 2026. This is unique to Schedule FA — almost every other ITR schedule is on a financial-year basis — and the mismatch is deliberate. The calendar year aligns with the reporting period used by foreign financial institutions under the Common Reporting Standard, which is how the Indian tax authorities receive matched data on Indian residents' overseas accounts.

What this means in practice:

1. Pull broker and bank statements for January-December 2025, not April-March.
2. If you bought a US stock on 15 February 2025 and sold it on 20 March 2025, it still belongs in your AY 2026-27 Schedule FA, even though both transactions sit inside FY 2024-25 for capital gains purposes.
3. Conversely, foreign assets acquired between 1 January 2026 and 31 March 2026 go into the AY 2027-28 Schedule FA, not this year's.

The income items on Schedule FA (dividends, interest, capital gains shown in the schedule for cross-reference) are also disclosed on a calendar-year basis inside Schedule FA itself, even though the same income is taxed on a financial-year basis in the main ITR. The two numbers will not match — Schedule FA shows calendar-year 2025 income; Schedule OS, Schedule CG and Schedule FSI show FY 2025-26 income. That is expected and not a discrepancy.

The sub-section walkthrough

Schedule FA in ITR-2 and ITR-3 for AY 2026-27 is organised as a series of tables, each one tailored to a category of foreign asset or interest. The structure has been broadly stable across recent CBDT notifications, with the most recent forms issued on 30 March 2026 along with corrigendum notifications during April 2026. The table letters and their scope are below.

Table A1 — Foreign depository accounts

A "depository account" in this context is a foreign bank account — a US checking account, a UK current account, a Singapore savings account. For each account you disclose:

• Country code and name
• Name and address of the financial institution
• Account number and status (owner / beneficiary / beneficial owner)
• Date the account was opened
• Peak balance during the calendar year (in INR)
• Closing balance on 31 December (in INR)
• Gross interest paid or credited during the calendar year (in INR)

A standalone US bank account at a non-brokerage institution (Wells Fargo, Chase, Bank of America) goes in A1; the cash leg inside a brokerage typically rolls up into the A2 disclosure for that broker.

Table A2 — Foreign custodial accounts

This is where most Indian-resident retail US investors spend the bulk of their disclosure time. A "custodial account" is a brokerage account holding securities — Interactive Brokers, Charles Schwab, Fidelity, Morgan Stanley Shareworks, E*TRADE, Vested's partner broker. One row per custodial account. Fields:

• Country and institution details (same as A1)
• Account number, status and date of opening
• Peak balance during the calendar year (in INR)
• Closing balance on 31 December (in INR)
• Gross amount paid or credited to the account during the calendar year, broken into:
  • Interest
  • Dividend
  • Proceeds from sale or redemption of investment
  • Other income

Note that A2 captures the account-level flows, not the security-level holdings. The actual stocks and ETFs inside the brokerage account are reported separately in A3.

Table A3 — Foreign equity and debt interest

This is the security-level disclosure. One row per holding — one row for NVDA, one row for MSFT, one row for VOO, one row for each bond. For each security:

• Country code and name
• Name and address of the entity (the issuer — Nvidia Corporation, Microsoft Corporation, Vanguard)
• Nature of the interest (equity / debt)
• Date of acquisition
• Initial value of investment (in INR, at SBI TTBR on the acquisition date)
• Peak value of investment during the calendar year (in INR)
• Closing value on 31 December (in INR)
• Total gross amount paid or credited during the calendar year (dividends and interest)
• Total gross proceeds from sale or redemption during the calendar year (in INR)

For RSU holders this row is filled per ticker, aggregating across all vested lots of that ticker. If you have 50 NVDA from three different vest events, you still file one A3 row for NVDA — with the initial value being the aggregate cost basis across those lots, the peak being the all-lot peak, and closing being the all-lot closing.

Table A4 — Foreign cash value insurance or annuity contracts

US-style whole-life policies with a cash surrender value, UK with-profits endowments, US 403(b) and similar annuity products belong here. Most Indian-resident retail investors do not hold these. If you do, A4 captures the institution, contract number, cash surrender value on 31 December, and gross amount paid or credited during the calendar year.

Tables B, C, D — financial interest, immovable property, other capital assets

The ITR-2 and ITR-3 Schedule FA for AY 2026-27 follows tables A1-A4 with three further blocks:

• Table B — Financial interest in any entity outside India. Partnership stakes in foreign LLPs, founder shares in a Delaware C-Corp, voting interests in any overseas company. This is where ESOPs or RSUs in private (non-listed) foreign entities typically sit, since they are not listed equity reported in A3.
• Table C — Immovable property outside India. A flat in London, land in Dubai, a holiday home in Lisbon. Disclose cost of acquisition, ownership status, and income earned (rent, etc.).
• Table D — Any other capital assets held outside India. Catch-all for art, jewellery, crypto held on overseas exchanges, and other foreign-situated capital assets that did not fit anywhere above.

The remaining blocks capture signing authority, trust interests and a sweep-up:

• Signing authority disclosures — corporate accounts you operate as an employee or director (a US dollar operating account of your employer that you can sign on but do not own). Peak balance and whether the income is taxable in your hands are reported.
• Trusts outside India in which you are trustee, beneficiary or settlor. Family trusts in Singapore, Jersey, the Caymans. Mostly relevant to founders and senior executives, not retail RSU holders.
• Income from any other source outside India that did not fit above — consulting income, freelance payments, royalty income from foreign sources.

The exact letter labels (E/F/G versus A5/A6/A7) vary slightly across CBDT notifications as forms are recut; the scope of what must be disclosed has been stable across recent assessment years.

Schedule TR — Tax Relief

Schedule TR is not technically part of Schedule FA but is its inseparable companion. It summarises, country by country, the foreign tax credit you are claiming inside the ITR — supported by Form 67 (being renumbered Form 44 from TY 2026-27) filed separately on the portal before the ITR. The TR figures must tie back to Schedule FSI (Income From Outside India), which lists the income on which the foreign tax was paid, country-wise. If TR claims relief on a dividend, FSI must report that dividend, FA must show the underlying stock — the chain must be unbroken.

A worked example: 50 NVDA, 30 MSFT, one Charles Schwab account

Take a realistic case. Anand is a senior engineer in Bangalore, ROR, with vested RSUs from a US multinational. During calendar year 2025 he held:

• 50 shares of NVDA, vested between January and October 2025 across four vesting tranches
• 30 shares of MSFT, vested in March and September 2025
• A Charles Schwab brokerage account holding both positions
• Quarterly dividends from both names, totalling USD 28 from NVDA and USD 102 from MSFT during the calendar year

Assume an SBI TTBR of approximately Rs 86 to Rs 88 across 2025, settling around Rs 87.50 on 31 December 2025, and assume the all-time peak portfolio value during the calendar year occurred on a day when the rate was approximately Rs 87.00.

Schwab account (Table A2). One row. Country = United States. Institution = Charles Schwab. Peak balance during 2025 — say USD 18,000 on a peak day — converts at Rs 87.00 to Rs 15,66,000. Closing balance on 31 December at USD 16,500 converts at Rs 87.50 to Rs 14,43,750. Gross dividend column: total dividend of USD 130, converted at the TTBR on each credit date and summed to approximately Rs 11,375.

NVDA holding (Table A3). One row. Entity = Nvidia Corporation. Nature = Equity. Initial value of investment is the sum across the four vest tranches of (shares × FMV at vest × TTBR on vest date) — for 50 shares averaging USD 130 at vest, approximately Rs 5,70,000. Peak value during 2025: if NVDA peaked at USD 175 on a day with TTBR Rs 87.00, peak = 50 × 175 × 87.00 = Rs 7,61,250. Closing on 31 December: 50 × USD 165 × Rs 87.50 = Rs 7,21,875. Gross dividend: USD 28 at the relevant TTBR, approximately Rs 2,450.

MSFT holding (Table A3). Identical mechanics. One row for the 30 MSFT shares.

Schedule TR / FSI. If Schwab withheld 25% on the dividends under the W-8BEN treaty rate, Anand has paid roughly USD 32.50 (~Rs 2,845) in US withholding. That is the figure that flows to Schedule TR as foreign tax credit and is reported in Schedule FSI as income arising from the United States. Schedule OS reports the same dividend on a financial-year basis for tax computation.

The fact that A2 captures the account-level flows while A3 captures the security-level holdings means dividends appear in both — once at A2 (account income) and once at A3 (security income). That is by design. The Income Tax Department uses the double entry to triangulate. Do not try to "net" it.

Common Schedule FA mistakes

A short list of what trips most filers, derived from cases that have actually escalated:

Peak vs closing confusion. Filers report only the closing balance and leave peak blank. Peak is mandatory. If your account was at USD 50,000 on 15 June 2025 and you wired most of it back before 31 December, the USD 50,000 peak still goes in — converted at the TTBR on the date the peak was hit, not at the year-end rate.

Using the wrong SBI rate. The Act specifies the SBI TT Buying Rate. SBI publishes both buying and selling daily; the selling rate is typically a few paise higher and using it inflates the INR figures. For weekends and holidays where SBI does not publish, use the immediately preceding working day's rate.

Missing the calendar-year window. Pulling statements for April-March instead of January-December is by far the most common error.

Not filing Schedule TR. Filers with a small dividend assume Schedule TR is optional. It is not — if you are claiming any foreign tax credit, TR must be populated and must tie to FSI and to your Form 67 / Form 44 filing.

Double-counting RSU vest income. RSU vesting is taxed as a salary perquisite, reported in Schedule S, not in Schedule FA. Schedule FA shows only the share itself, dividend and sale proceeds — not the perquisite value at vest. Putting it into FA creates a mismatch with Schedule S that an automated notice will flag. See the complete RSU guide for how the two interlock.

Omitting a closed account. A US account open during 2025 but closed before 31 December still belongs on Schedule FA — status "Owner during the year", peak as actual, closing as zero. Omitting because closing is zero is exactly the pattern the Black Money Act targets.

Forgetting ESPP fractional shares. ESPP plans frequently leave a handful of fractional shares in a custodial account. They are still foreign equity and need to be picked up in A2 and A3.

What you need before you start

Before opening the Schedule FA worksheet on the e-filing portal, assemble:

• Calendar-year statements from every foreign broker and bank. Most US brokers (Schwab, Fidelity, Interactive Brokers) provide a year-end statement on a calendar-year basis automatically — that is the right document.
• Form 1099-DIV and 1099-B (or equivalents). These document the gross dividend and any sale proceeds, plus the US withholding tax that supports your Form 67 / Form 44 claim.
• A daily SBI TTBR table for the relevant currency. SBI publishes daily; archived rates are available via SBI and through several third-party aggregators. The rate columns you need are "TT Buying" for the currency in question.
• Prior-year Schedule FA, if filed. Carryforward of opening positions, prior-year disclosures of the same custodial account, and consistency in entity names, country codes and account numbers reduces audit risk substantially.
• Vest-date FMV records for every RSU lot. These establish the initial value of investment column in Table A3 and are also what supports the perquisite in Schedule S. For a working method, see the cost-basis tracking guide.
• Form 67 / Form 44 acknowledgement. Filed on the portal before the ITR. Schedule TR will not flow correctly to your tax computation unless the supporting Form is on record.

The mechanical work of converting holdings, dividends, peak and closing balances at the right SBI TTBR per date is exactly the workflow our Schedule FA helper tool automates — pull a broker CSV, the tool computes each row in INR at the correct dated TTBR and outputs a Schedule FA-ready summary.

Penalty exposure under the Black Money Act

The reason Schedule FA is treated so seriously is the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 — the parallel statute that runs alongside the Income-tax Act for foreign-asset matters. Three provisions matter.

Section 42 — failure to file a return. A flat Rs 10 lakh penalty for every year a resident holds a foreign asset and fails to file an income tax return.

Section 43 — non-disclosure or inaccurate disclosure in the return. A flat Rs 10 lakh penalty for every year in which the return is filed but foreign assets are not disclosed in Schedule FA or are disclosed inaccurately. From 1 October 2024 (via the Finance (No. 2) Act, 2024) the Section 43 penalty does not apply where the aggregate value of the undisclosed foreign assets (excluding immovable property) is Rs 20 lakh or less. The exemption is from the penalty, not from the disclosure obligation. You still need to file Schedule FA.

Sections 49 and 50 — prosecution. Wilful failure to furnish a return where a foreign asset is held, or wilful failure to disclose it in the return, can attract rigorous imprisonment ranging from six months to seven years, plus a fine. The same Finance Act amendment narrowed prosecution scope where the value is below Rs 20 lakh (excluding immovable property), but did not remove the underlying offence.

Tax + 120% penalty on undisclosed assets. Where a foreign asset is treated as undisclosed in assessment, tax is levied at 30% flat on its value and a further penalty equal to three times that tax is imposed — effectively 120% of asset value, on top of the asset itself. This is the regime that has produced multi-crore demands against Indian executives whose vested RSUs were never disclosed.

ITAT precedent has, in some cases, taken a softer line on inadvertent omissions — the Mumbai Bench has held that the Section 43 penalty is discretionary and that a bona fide belief, for instance an asset acquired through tax-paid LRS remittances that the assessee genuinely thought was already covered, can be a defence. The discretion is real but exercised case by case, not as a general waiver.

If you discover historical non-disclosure, do not wait for a notice. CBDT has periodically opened voluntary disclosure windows — most recently a campaign with a 31 December 2025 deadline and, in Budget 2026, the Foreign Assets of Small Taxpayer Disclosure Scheme (FAST-DS). Penalties for voluntary correction are typically a fraction of what the department imposes after it comes calling. Speak to a CA before filing a revised return; the framing matters.

Tools to make this less painful

The mechanical work of Schedule FA — converting balances at dated SBI TTBRs, aggregating lots across vest events, splitting account-level versus security-level disclosures — is exactly the kind of repetitive task that wastes a CA's time and yours. We built tooling so you can do it yourself or arrive at your CA's office with the rows already populated.

• The Schedule FA helper accepts broker exports and produces table-by-table Schedule FA rows in INR at the correct SBI TTBR per date.
• The LRS guide covers the remittance side that fed your foreign assets in the first place.
• The Form 67 / Form 44 guide covers the foreign tax credit chain that ties to Schedule TR.
• The US investing hub is the directory entry for the full set of US-specific compliance posts.
• The US dividend withholding guide walks through the W-8BEN, the 25% treaty rate and how that flows back into Schedule TR.

A clean filing sequence

The canonical order for AY 2026-27: establish your residential status (ROR files; RNOR and NR skip), pull every foreign statement for 1 January to 31 December 2025, map each asset to its table (A1 bank accounts, A2 brokerage accounts, A3 securities, A4 cash-value insurance, B-D financial interest / property / other), convert every figure at the SBI TTBR on the relevant date, file Form 67 / Form 44 on the portal before the ITR, populate Schedule TR and Schedule FSI so the FTC claim ties to the underlying income, and then file ITR-2 or ITR-3 with Schedule FA complete. Retain broker statements, the SBI TTBR table and the Form 67 acknowledgement for at least 16 years — the Black Money Act has no time-bar on reassessment for undisclosed foreign assets.

Schedule FA is annoying, not difficult. Get the residence test right, the calendar-year period right, the table mapping right and the SBI TTBR right, and the rest is mechanical. The cost of skipping it is wildly disproportionate to the cost of doing it.