Returning to India? Foreign asset disclosure just got harder to skip

Foreign asset disclosure — Schedule FA in your ITR — has always applied only to individuals classified as Resident and Ordinarily Resident (ROR). If you're genuinely non-resident, this doesn't touch you. It also doesn't touch you during your RNOR window — the 2–3 years after moving back to India when you're a resident for tax purposes but not yet "ordinarily" resident.

What's new: from July 2026, the tax department has started feeding AEOI data — foreign bank and account details shared automatically by over 100 countries under CRS and FATCA — directly into your AIS (Annual Information Statement). The disclosure requirement itself is unchanged. What's changed is detection: mismatches between your declared assets and what foreign tax authorities report now surface automatically, rather than depending on manual scrutiny.

Who this affects: returning NRIs who've crossed from RNOR into ROR status, and any Indian resident holding a foreign bank account, brokerage account, RSUs, or overseas property.

What to do: if you're ROR and hold foreign assets, foreign bank accounts, or overseas equity (including vested RSUs), disclose them in Schedule FA — even if they earned zero income during the year. It runs on the calendar year (1 January–31 December), not the Indian financial year, which trips up a lot of filers. Non-disclosure carries a flat ₹10,00,000 penalty per year under the Black Money Act, with a ₹20,00,000 safe-harbour exemption for small movable-asset holdings. If you've missed a past year's disclosure, a revised or updated return, filed proactively, is a materially better position than waiting for a notice.