RSU Schedule FA India — Vested Shares, Unvested Units, Table A3

8 min read · Updated June 2026 · Applies to AY 2025-26 and AY 2026-27

1. RSU Basics — Grant, Vest, Settlement

A Restricted Stock Unit (RSU) is a promise by your employer to give you shares on future dates, subject to continued employment (the vesting schedule).

• Grant date — employer awards RSUs. No shares yet, no tax event in India.
• Vest date — shares become yours. In India, this is a taxable perquisite: FMV on vest date × shares = value added to salary income, taxed as per your slab.
• Settlement date — shares deposited to your Fidelity brokerage account (usually same day as vest date or T+2).
• Sale date — you sell shares. Capital gains tax applies (STCG or LTCG depending on holding period from vest date).

For Schedule FA purposes, the relevant event is vest date — that is when you acquire beneficial ownership of the shares.

2. When RSUs Trigger Schedule FA Obligation

Schedule FA disclosure is required if you held the vested shares (or had unvested units) at any point during the calendar year ending Dec 31 (the period the ITR form prescribes — e.g. CY 2024 for FY 2024-25 / AY 2025-26). Specifically:

• You held vested RSU shares at any time during the calendar year → disclose in Table A3
• You had unvested RSU units during the calendar year → disclose in Table A3 as beneficial interest (conservative practice; some CAs defer until vesting)
• You sold all shares during the calendar year → still disclose in Table A3 (closing value 0, sale proceeds reported)
• You had RSU shares or units on any single day during the FY → Table A2 peak balance includes that period

3. Vested RSU Shares — Table A3 Fields

For each vest lot held at any time during the calendar year, create one row in Table A3:

4. Unvested RSU Units — Also Table A3

This surprises many people: unvested RSUs must also be disclosed in Schedule FA Table A3.

Unvested RSUs give you a beneficial interest in foreign equity — you have a legal right to receive shares upon meeting vesting conditions. The CBDT has clarified that such beneficial interests in foreign assets are disclosable under Schedule FA.

If you have unvested units from multiple grants (e.g. 2022, 2023, 2024 grants), you can aggregate all unvested units into one row. Fidelity's year-end statement shows total unvested units.

5. Acquisition Date: Vest Date, Not Grant Date

The acquisition date for Schedule FA Table A3 is the date shares were deposited to your Fidelity account after vesting — this is the vest date (or settlement date, which is usually the same day or T+2).

Your Open Lots CSV from Fidelity has a "Date acquired" column — this is the vest date for RSU lots. Use this date directly.

Your Open Lots CSV also has a "Grant date" column — this is the original grant date. Do not use this as the acquisition date in Table A3.

6. Initial Value Calculation — Rule 115

Initial Value = FMV on vest date × number of shares × SBI TTBR on vest date

Three things to get right:

1. FMV on vest date — use the closing stock price on the vest date (or nearest preceding trading day if the vest fell on a weekend/holiday). For Fidelity, this is the price Fidelity used to compute your perquisite income — visible on your RSU Statement or Form 1099-B.
2. Number of shares — the shares deposited to your account on that vest date, after tax withholding. Fidelity typically withholds shares for TDS. The quantity in your Open Lots CSV is the after-withholding quantity — use this.
3. SBI TTBR on vest date (Rule 115) — use the SBI Telegraphic Transfer Buying Rate on the exact vest date, or nearest preceding working day if the vest date was a weekend/holiday. See Rule 115 guide →

7. Multiple Vest Lots — One Row Each

If your RSU grant vests quarterly over 4 years, you accumulate 16 vest lots. Each vest lot gets its own row in Table A3. This is the most tedious part of manual Schedule FA filing — 15–20 rows, each requiring a separate SBI TTBR rate lookup and calculation.

Your Fidelity Open Lots CSV lists each lot separately with its acquisition date and cost basis. ITRFA.in reads this and generates one Table A3 row per lot automatically, fetching the correct SBI TTBR rate for each acquisition date.

8. Lots Sold During the Year — Still in Table A3

If you held RSU shares at any time during the calendar year and sold them — whether mid-year or after Dec 31 — those lots must still appear in Table A3 for the year they were held. Lots sold during the calendar year are reported with a closing value of 0 and their sale proceeds; lots sold after Dec 31 still show their Dec 31 closing value.

Sold lots no longer appear in your Fidelity Open Lots CSV (they're closed). This is why uploading the Closed Lots CSV is important — ITRFA.in identifies every lot whose holding overlapped the calendar year and includes it in Table A3 automatically.

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