Short answer: Schedule FA covers every foreign asset or account you held at any time during the calendar year, whether as legal owner, beneficial owner or beneficiary, plus foreign accounts you can sign on without owning. The main brokerage account is rarely what gets missed. It is the old student or old-job bank account, the 401(k), the cash left in the RSU account, a Wise balance, a policy with a surrender value, crypto on an overseas exchange, a stake in a foreign company, a family trust, or an employer account you are a signatory on. The ₹20 lakh Black Money Act threshold affects the penalty, not whether you fill in the schedule.
These are also the items most likely to sit behind the department's current emails. If you received one, start with the income tax email on overseas financial interests.
Four rules decide it.
- Only a resident and ordinarily resident individual fills it. The department's own guide says it need not be completed by someone who is non-resident or resident but not ordinarily resident (RNOR) for the year.
- The period is the calendar year, not the Indian April-to-March year. For AY 2026-27 that is 1 January to 31 December 2025.
- Anything held at any time in that year counts. An account closed in March, or shares sold in June, still go in.
- Ownership is wider than your name on the account. You report as legal owner, as beneficial owner (you provided the money, directly or indirectly), or as beneficiary (you benefit from an asset someone else paid for).
Schedule FA is in ITR-2 and ITR-3. ITR-1 and ITR-4 do not have it, so anyone with a foreign asset cannot use them.
| Table | Title | Typical contents |
|---|
| A1 | Foreign depository accounts | Bank accounts; peak and closing balance, interest |
| A2 | Foreign custodial accounts | Brokerage and equity-plan accounts |
| A3 | Foreign equity and debt interest | Each share or bond holding |
| A4 | Foreign cash value insurance or annuity contracts | Policies with a surrender value |
| B | Financial interest in any entity outside India | Stakes in foreign companies, LLCs, partnerships |
| C | Immovable property outside India | Flats, houses, land |
| D | Other capital assets outside India | Anything not covered above |
| E | Accounts with signing authority | Accounts you can operate but do not own, not reported in A1 to D |
| F | Trusts created outside India | As trustee, beneficiary or settlor |
| G | Other income from outside India | Income not covered in A1 to F |
Values are converted at SBI's telegraphic transfer buying rate on the relevant date: the date of the peak, the date of investment, or 31 December.
| Asset | Table | Counts toward ₹20 lakh? |
|---|
| Dormant bank account from studying or working abroad | A1 | Yes |
| 401(k), IRA and similar retirement accounts | A2 in common practice | Yes |
| Employer brokerage account and the cash in it | A2, holdings in A3 | Yes |
| Wise, Revolut, PayPal balances held abroad | A1 in common practice | Yes |
| Foreign insurance with a cash value | A4 | Yes |
| Crypto on a foreign exchange | D in common practice | Yes, if treated as a foreign asset |
| Stake in a foreign company or LLC | B | Yes |
| Foreign trust, as beneficiary or settlor | F | Unsettled |
| Signing authority on someone else's account | E | Better view no; unsettled |
The old student or old-job bank account
The account opened for a master's degree in 2014, or during a posting to Singapore, with a few hundred dollars still in it. It goes in Table A1 with its peak balance, closing balance and interest for the year. A small balance is not an exemption.
These accounts are the ones CRS reports most reliably, because foreign banks report year-end balances and interest on accounts held by Indian tax residents. They are also the classic Entry 2 case under FAST-DS: an asset funded from income earned while non-resident and not reported on becoming resident, which settles for a flat ₹1,00,000 rather than 60% of value. See the FAST-DS pillar. If it goes to FAST-DS, the account is valued at the sum of every deposit since it was opened, so the full statement history matters.
401(k), IRA and other foreign pensions
A 401(k), an IRA, a UK workplace pension or SIPP, or a Canadian RRSP is an account held outside India, and it belongs in Schedule FA. The form does not name retirement accounts. Most practitioners report defined-contribution accounts in Table A2, because the plan holds investments on your behalf. A defined-benefit entitlement with no account balance is a less settled case.
Section 89A of the 1961 Act (section 158 of the 2025 Act) lets a resident defer tax on the growth in a retirement account maintained in a notified country (the US, the UK and Canada) until withdrawal, if Form 10-EE is filed. That defers the tax. It does not remove the disclosure.
Do not rely on AIS here. What the US sends India under FATCA is income paid, such as interest and US-source dividends, not account balances, so a 401(k) that paid nothing out in the year may never appear.
The employer brokerage account, and the cash beside the shares
Most people report the vested RSUs. Fewer report the account, and fewer still the cash in it.
- The account (E*TRADE, Fidelity, Schwab, Morgan Stanley at Work) goes in Table A2, with its peak and closing balance for the calendar year.
- Each holding goes in Table A3: vesting date as the acquisition date, the vesting-date value as the initial value, then peak and closing value.
- Uninvested cash from sell-to-cover residue, dividends or fractional-share sales is part of the account's balance, so it sits within the A2 figures. Where the platform sweeps cash into a partner bank, some practitioners show that balance in A1 instead. It must appear once, and only once.
- ESPP shares are reported the same way. Unvested RSUs are not yet held and are not reported.
The field-by-field mapping is in Schedule FA from your broker statement, and platform specifics in Schedule FA for Fidelity, Schwab and Morgan Stanley.
Wise, Revolut and PayPal balances
A balance held with a provider outside India is a foreign asset. The form does not name e-money, and the common treatment is Table A1, since it is money held for you rather than securities.
The reporting position is changing. A deposit with a bank has always been within the Common Reporting Standard (CRS). E-money was brought into CRS by the OECD's 2023 amendments, which the EU applied from 1 January 2026, with first reports due in 2027. Wise states that it collects tax-residence self-certifications and reports under CRS. So a balance from earlier years may not appear in your AIS, but it was still reportable in Schedule FA for each year you held it while resident.
Foreign insurance with a cash value
A life policy taken out abroad that builds a cash or surrender value, such as whole-life cover or an investment-linked policy, goes in Table A4, with the value at year end and anything paid out. Pure term cover with no surrender value is not an asset to report. Cash-value policies are within CRS, so these can appear in AIS.
Crypto on a foreign exchange
There is no crypto table in Schedule FA and no CBDT clarification on where a crypto holding is located. The cautious and common approach is to disclose holdings on an exchange outside India in Table D, other capital assets, with gains reported separately in the virtual digital asset schedule. India is expected to start exchanging information under the OECD's Crypto-Asset Reporting Framework from 2027, so this will not stay out of the department's data.
A stake in a foreign company, LLC or partnership
Shares in a friend's Delaware start-up, a US LLC set up for freelance work, or an interest in a foreign partnership usually go in Table B, financial interest in any entity outside India (some practitioners put a plain minority shareholding in A3; what matters is that it appears once). The department's guide makes Table B wide: it includes holdings through an agent or nominee, and entities in which you own any share, voting power or interest in profits. Listed shares held through a broker belong in A3 instead.
A foreign trust
Being a trustee, beneficiary or settlor of a trust set up under foreign law goes in Table F. A discretionary family trust abroad of which you are one of several beneficiaries is the usual miss. The Black Money Act's reporting penalty expressly reaches assets of which you are a beneficiary. How to value a discretionary beneficiary's interest for the ₹20 lakh test is not settled, so treat it with care.
Signing authority on an account you do not own
A finance employee authorised on a foreign group company's account, or a child holding a power of attorney over a parent's account abroad, goes in Table E. That table covers foreign accounts you can operate that are not already reported in A1 to D, with the peak balance or value.
The account is not your asset. The better view is that it does not count toward your ₹20 lakh aggregate, because the penalty provision is framed around assets held as owner or beneficiary, but no authority settles it. The disclosure in the return is required either way.
From 1 October 2024, the provisos to sections 42 and 43 of the Black Money Act take assets other than immovable property, with an aggregate value up to ₹20 lakh, outside the penalties for not reporting them. A CBDT instruction of 18 August 2025 says prosecution will not be started where that proviso applies.
Three limits:
- It does not remove the obligation to complete Schedule FA. It removes the penalty for failing to.
- It is an aggregate. Every item in the table above that counts goes into one total.
- Whether it covers defaults before 1 October 2024 is arguable, as the site's FAST-DS pillar explains.
The detail is in the ₹20 lakh threshold.
| Year of the omission | Route | Deadline |
|---|
| AY 2026-27 (calendar year 2025) | Revised return | 31 March 2027; fee under s.234-I if revised late in the window |
| AY 2025-26 and earlier | FAST-DS: Entry 2 (flat ₹1,00,000) if funded from non-resident-period or already-taxed income; Entry 1 (60% of value) if the source is unexplained | 31 December 2026 |
The revised-return route is in missed Schedule FA? The revised return window. For the tax and reporting of RSUs and foreign brokerage accounts generally, see foreign income, RSU and ESOP filing.
This note lists the foreign assets most often left out of Schedule FA and where each is reported. It is not advice on any individual's position. Table letters and titles follow the Income Tax Department's published guide to Schedules FSI, TR and FA; confirm them against the ITR-2 or ITR-3 utility for the year you are filing. Where the form does not name an asset (retirement accounts, e-money, crypto), the table given is common practice rather than a CBDT ruling. Residential status for each year, the source of each asset's funding and the value of each item should be confirmed before a return is revised or a FAST-DS declaration is filed.