Schedule FA from Fidelity NetBenefits — Complete Walkthrough
10 min read · Updated June 2026 · Applies to AY 2025-26 and AY 2026-27
TL;DR: Schedule FA is mandatory for Indian residents (ROR) who hold a Fidelity NetBenefits account — even if you made no sales and received no dividends this year. ₹10 lakh penalty per year of non-disclosure under the Black Money Act, 2015.
Schedule FA is a section of ITR-2 and ITR-3 where Indian residents disclose foreign financial assets. It was introduced under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015.
You must file Schedule FA if you are a Resident and Ordinarily Resident (ROR) in India and hold any of the following:
Foreign bank or brokerage accounts (including Fidelity NetBenefits)
Foreign equity shares — whether vested RSUs, ESPP purchased shares, or direct purchases
Beneficial interest in foreign trusts (Fidelity Stock Plan Services LLC Participant Trust qualifies)
Any other foreign financial asset with value > ₹0
There is no minimum threshold. Even ₹1 of foreign assets requires disclosure. Non-residents (NR) and Not Ordinarily Resident (NOR) are exempt.
A typical Fidelity NetBenefits account for an Indian employee has three distinct components, each requiring separate disclosure:
Account Component
Schedule FA Table
What to Report
Stock Plan Account (custodial brokerage)
Table A2
Peak balance, closing balance (Dec 31), dividends, sale proceeds
Vested RSU shares held
Table A3
One row per acquisition (vest) lot — initial value, peak, closing
ESPP purchased shares held
Table A3
One row per purchase date — initial value, peak, closing
Unvested RSU units
Table A3
Beneficial interest — one row per grant
Fidelity Participant Trust
Table F
Trust details (optional but recommended)
3. Which CSVs to export from Fidelity
Login to netbenefits.fidelity.com. You need three files:
Path: Stock Plan Account → View Share Details → Open Lots tab → Export When prompted, choose: Asset Currency (USD)
This file has one row per lot: acquisition date, quantity, cost basis per share, total cost basis, share source (RS = RSU, SP = ESPP), grant date.
Used for: Table A3 initial value INR (cost basis × SBI TTBR on acquisition date per Rule 115).
Path: Stock Plan Account → Activity → Transaction History → Export Date range: January 1 → December 31 of the calendar year
(e.g., Jan 1 2025 – Dec 31 2025 for FY 2025-26 — Schedule FA reports the calendar year ending Dec 31)
Needed only if you sold shares. Lots held at any time during the calendar year — including ones you sold during it — must appear in Table A3 (sold lots show a closing value of 0), but they no longer appear in Open Lots.
If you never sold, skip this file.
4. Table A2 — Foreign Custodial Account
Table A2 covers the Fidelity stock plan account itself (the brokerage wrapper). One row per account.
Field
What to Enter
Source
Country
United States (US)
Fixed
Name of Institution
Fidelity Investments (NetBenefits)
Fixed
Account Number
Your participant number (e.g. I02483034)
Fidelity statement
Status of Account
Active
Fixed
Peak Balance (INR)
Max(shares × stock price) across the calendar year (Jan–Dec) × SBI TTBR
yfinance + Rule 115
Closing Balance (INR)
Shares × stock price on Dec 31 × SBI TTBR Dec 31
yfinance + Rule 115
Gross Amount Paid/Credited (INR)
Dividends + money market income in the calendar year (Jan–Dec) × SBI TTBR
Transaction History
Gross Proceeds (INR)
Sale proceeds from stock sales in the calendar year (Jan–Dec) × SBI TTBR
Transaction History
Critical: Closing balance uses Dec 31, not March 31. Fidelity's accounting period is January–December (calendar year). The ITR form says "closing balance as of the last date of the accounting period of the institution" — for Fidelity, that is December 31.
5. Table A3 — Foreign Equity Interest
Table A3 requires one row per lot (acquisition date) for every foreign equity interest. For Fidelity, this means one row per RSU vest lot and one row per ESPP purchase lot.
Field
RSU Vested Lot
ESPP Purchased Lot
Entity Name
Company name (e.g. ServiceNow Inc)
Company name
Nature of Entity
Equity shares — N shares acquired DD/MM/YYYY
ESPP shares — N shares purchased DD/MM/YYYY
Date of Acquiring
Vest date (not grant date)
ESPP purchase date
Initial Value (INR)
Market price on vest date × shares × SBI TTBR vest date
FMV on purchase date × shares × SBI TTBR purchase date
Peak Value (INR)
Lot's share of max portfolio value during FY × SBI TTBR
Same
Closing Value (INR)
Shares × Dec 31 price × SBI TTBR Dec 31
Shares × Dec 31 price × SBI TTBR Dec 31
Total Income (INR)
0 (dividends go in Table A2)
0
If you have 15 RSU vest lots across 3 grant years, you need 15 rows in Table A3. This is why manual filing is so tedious — ITRFA.in generates all rows automatically from the Open Lots CSV.
For unvested RSUs: also disclose in Table A3 as beneficial interest. Initial value = 0 (you haven't paid for them yet). Closing value = unvested units × Dec 31 stock price × SBI TTBR. See full RSU guide →
6. Table F — Fidelity Participant Trust
Fidelity Stock Plan Services LLC operates a participant trust to hold unvested RSU and ESPP shares on your behalf. Technically, as a plan participant, you have a beneficial interest in this trust — making it a foreign trust you should disclose in Table F.
In practice, many CAs omit Table F on the grounds that the beneficial interest is already captured in Table A3. However, a conservative filing includes Table F. Fields required:
Trust Name: Fidelity Stock Plan Services LLC Participant Trust
Country: United States
Settlor / Employer: Your employer name and address
Date of creation: Your first RSU grant date (approximate)
Beneficiary details: Beneficial interest as plan participant
7. Five common mistakes that trigger scrutiny
Using March 31 as closing date instead of Dec 31.
Fidelity's accounting period ends Dec 31. The ITR field "closing balance as of last date of accounting period" must use Dec 31 stock price and Dec 31 SBI TTBR rate — not March 31.
Using Rule 26 exchange rate (preceding month) instead of Rule 115 (exact date).
Rule 26 applies to salary income conversion. Schedule FA values must use Rule 115: SBI TTBR on the exact acquisition/event date. Using the wrong rule can cause 15–20% difference in INR values. See Rule 115 guide →
Using one row for all RSU lots instead of per-lot rows.
Table A3 requires one row per acquisition (vest) date. Aggregating all RSU lots into one row is incorrect and makes values unverifiable.
Using discounted ESPP purchase price as initial value.
If your employer reported the ESPP discount as perquisite in Form 16 (which most do), your Indian cost of acquisition is FMV on purchase date — not the discounted price. Using the discounted price understates initial value. See ESPP guide →
Omitting the year entirely when no sales occurred.
Schedule FA is mandatory every year you hold foreign assets — regardless of whether you sold anything or received any income. Many people mistakenly think "no income = no filing obligation." This is incorrect.
8. Automate with ITRFA.in
Manual filing from Fidelity data involves:
Downloading 2–3 CSVs from Fidelity
Looking up SBI TTBR rates for every acquisition date (can be 10–20 dates)
Looking up stock prices for every month-end to find peak balance
Computing INR values for every lot
Entering 15–30 rows into ITR-2
ITRFA.in does all of this from your CSV upload. Upload Open Lots + Transaction History, verify the auto-fetched exchange rates on the review screen, and download ITR-ready JSON + Excel in under 2 minutes.
Generate Schedule FA automatically
Upload Fidelity CSVs → get Table A2, A3, F with correct SBI TTBR rates. Takes 2 minutes. ₹399 for full INR values + JSON + Excel download.