Did Your CA File Schedule FA Correctly? A Self-Audit Checklist
6 min read · Published July 2026 · Applies to AY 2025-26 and AY 2026-27
If you hold US employer stock and file through a chartered accountant, you are still the one who signs the return. It is worth spending ten minutes checking what was actually filed, especially for the years before Schedule FA became a routine part of RSU/ESPP filings for many practices.
Step 1 — get your actual filed return, not a summary
Log in to the income tax e-filing portal → e-File → Income Tax Returns → View Filed Returns, and download the ITR in JSON or PDF for each year you want to check. A computation sheet or Form 16 from your CA is not the same thing — you need the actual filed schedules.
The 6-point checklist
| # | Check | What "wrong" looks like |
|---|---|---|
| 1 | Schedule FA section exists at all, with entries in Table A2 (account) and Table A3 (shares) | ITR-1 was filed (it has no Schedule FA), or ITR-2/ITR-3 was filed but the Schedule FA section is blank |
| 2 | Every foreign broker account is listed — not only the one that had a sale that year | You held RSUs at two employers over the years (job change) but only the most recent broker appears |
| 3 | Peak value and Dec 31 closing value are both filled, and the closing date is December 31, not March 31 | Values look identical to your salary-schedule figures, or the closing date matches the Indian financial year end instead of the calendar year |
| 4 | Unvested RSUs are disclosed as beneficial interest, if you had any that year | Only vested/sold shares appear; unvested grants are absent entirely |
| 5 | Form 67 was filed on or before the return, if a foreign tax credit was claimed | Schedule TR shows a credit claimed, but no Form 67 was filed, or it was filed after the return — see Form 67 & FTC |
| 6 | Sold/sell-to-cover lots still appear in Table A3 with closing value 0 plus proceeds — they are not simply dropped | A lot sold mid-year is missing entirely from Table A3, as if it never existed |
"But my RSU income is in Form 16 and I reported the sale in Schedule CG"
That is a common and reasonable-sounding assumption — and it is the single most frequent gap this checklist catches. Form 16 and Schedule CG report income: the perquisite value at vest, and the gain or loss on a sale. Schedule FA reports the asset itself — the brokerage account and the shares in it — and applies every year you hold the asset, whether or not it produced any income that year. One does not substitute for the other; see why "I already paid tax" doesn't cover the disclosure obligation.
If you find a gap
- Current/still-open assessment year: file a revised return with the corrected Schedule FA before the revision deadline — see Schedule FA deadlines.
- Past, closed years: talk to a CA about your options. If the underlying RSU/ESPP income was genuinely taxed each year and only the Schedule FA disclosure was missed, this is exactly the fact pattern the FAST-DS 2026 amnesty scheme is designed for, once it opens. Read what the Black Money Act penalty actually is before assuming the worst — and before assuming nothing is wrong.
- Going forward: you don't need to switch CAs to fix this — sharing this checklist with your current one, and pulling your own broker export as a cross-check, is usually enough.
Upload your broker CSVs and compare ITRFA.in's Table A2/A3 output against what your CA is about to file — a quick second opinion before you sign.
Generate your Schedule FA →Related guides
- Black Money Act & Schedule FA — the penalty for not disclosing
- FAST-DS 2026 — foreign asset amnesty for missed past years
- Who must file Schedule FA — ROR vs RNOR vs NRI
- 10 common Schedule FA mistakes