Schedule FA from Fidelity NetBenefits — Complete Walkthrough
10 min read · Updated July 2026 · Applies to AY 2025-26 and AY 2026-27
1. What is Schedule FA and who must file
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.
See full penalties and legal obligations →
2. Which Fidelity accounts need disclosure
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:
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 CBDT's Schedule FA filing instructions — see the free TTBR lookup). Which value goes in which column: Table A2 vs A3 guide.
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)
Contains: RSU vests, ESPP purchases, dividends, money market income, stock sales, NRA withholding.
Used for: Table A2 gross income (dividends), gross proceeds (sales), NRA withholding for DTAA cross-check.
Only filing Schedule FA? Jan 1 – Dec 31 is enough. Also filing Schedule CG, OS/FSI, or claiming foreign tax credit on Form 67? Those run on India's financial year (Apr–Mar), not the calendar year — export 15 months instead, Jan 1 2025 – Mar 31 2026, so dividends, sales and withholding from Jan–Mar 2026 aren't missed. If your broker's date picker caps at 12 months, export twice — the app accepts multiple Transaction History files, just select both when uploading.
Choose: Asset Currency (USD)
Check the date-range selector before exporting. Previously Held Shares has its own period picker, separate from the Transaction History export above, and it does not default to the full year — only filing Schedule FA? Jan 1 – Dec 31 is enough. Also filing Schedule CG, OS/FSI, or Form 67? Set it to Jan 1 2025 – Mar 31 2026 (15 months) instead, so sales from Jan–Mar 2026 aren't silently dropped. If the picker caps shorter, export it twice and upload both.
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 under Current shares.
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 Name and Code | 2-UNITED STATES OF AMERICA (dropdown selection, not a typed code) | Fixed |
| Name of Institution | Fidelity Investments (NetBenefits) | Fixed |
| Account Number | Your participant number (e.g. I02483034) | Fidelity statement |
| Status | Owner, Beneficial Owner, or Beneficiary — your relationship to the account (there's no "Active/Inactive" option) | Fixed — usually Beneficial Owner |
| Peak Balance (INR) | Max(shares × stock price) across the calendar year (Jan–Dec) × SBI TTBR on that peak date | yfinance + SBI TTBR (peak date) |
| Closing Balance (INR) | Shares × stock price on Dec 31 × SBI TTBR Dec 31 | yfinance + SBI TTBR (exact date) |
| Nature of Amount + Amount | One dropdown value (Dividend/Interest/Proceeds from Sale/Other) + its own amount, per row | Transaction History |
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 on that peak date | Same |
| Closing Value (INR) | Shares × Dec 31 price × SBI TTBR Dec 31 | Shares × Dec 31 price × SBI TTBR Dec 31 |
| Total Income (INR) | 0, unless a dividend can be matched to this specific holding — then it goes here instead of only in Table A2 | Same |
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 Current Shares 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 OF AMERICA
- 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 Income-tax Rule 115's preceding-month rate instead of the correct exact-date rule for Schedule FA. Income-tax Rule 115's preceding-month rate applies to computing salary/dividend/capital-gains income. Schedule FA values must use CBDT's Schedule FA filing instructions: 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 Current Shares + Transaction History, verify the auto-fetched exchange rates on the review screen, and download ITR-ready JSON + Excel in under 2 minutes.
Upload Fidelity CSVs → get Table A2, A3, F with correct SBI TTBR rates. Takes 2 minutes. ₹399 for full INR values + JSON + Excel download.
Convert Fidelity CSV to Schedule FA →