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Who Must File Schedule FA? ROR vs RNOR vs NRI

6 min read · Updated July 2026 · Applies to AY 2025-26 and AY 2026-27

One-line answer: Only a Resident and Ordinarily Resident (ROR) must file Schedule FA. RNOR and NRI taxpayers do not disclose foreign assets there.
In a hurry? If you're ROR, get it done — upload your Fidelity CSVs and file in 2 minutes. Upload now →

Schedule FA discloses foreign assets and foreign income. Whether you must fill it depends entirely on your residential status for the financial year — not on your citizenship or where your employer is.

The three statuses

  • ROR — Resident and Ordinarily Resident: taxed on global income and must file Schedule FA for all foreign assets, including US RSUs, ESPP and Fidelity accounts.
  • RNOR — Resident but Not Ordinarily Resident: a transitional status (common in the first one or two years after returning to India). Generally not required to disclose foreign assets in Schedule FA.
  • NRI — Non-Resident: taxed only on Indian income; not required to file Schedule FA.

How residency is decided (high level)

You are a Resident for a financial year if you are in India for 182 days or more, or 60+ days in the year plus 365+ days across the preceding four years. A resident is Ordinarily Resident (ROR) unless they were non-resident in 9 of the previous 10 years, or in India for 729 days or fewer in the previous 7 years — in which case they are RNOR. Deemed-residency rules can also apply to high-income Indian citizens not taxed elsewhere.

The year you return to India from a US assignment is the one to get right. Many people are RNOR that year (no Schedule FA), then become ROR the next year (Schedule FA required). Check your day count carefully.

If you are ROR, what do you disclose?

  • Fidelity stock plan / brokerage account → Table A2
  • Vested RSU shares and ESPP shares → Table A3
  • Unvested RSUs (beneficial interest) → Table A3
  • The asset is reported even if it earned no income during the year.

Returning NRI with a foreign bank account too?

If you became ROR after returning to India and still hold a foreign bank account — not just the brokerage account holding your RSUs/ESPP — that bank account is a separate foreign asset and needs its own Schedule FA entry (typically Table A1, for foreign depository/custodial bank accounts), reported the same way and for the same period as your brokerage holdings. Closing an account mid-year doesn't remove the obligation to disclose it for the period it was open.

Holding RSUs across multiple broker accounts?

If you've changed employers, or your equity plan moved brokers, you may hold foreign shares across more than one account — for example, a Fidelity account from a previous job and an E*TRADE or Morgan Stanley account from a current one. All of them belong in the same Schedule FA, as separate Table A2 rows (one per account) and Table A3 rows for each account's holdings — not as separate filings or separate uploads to the ITR portal. A common gap: only the most recently active account gets reported, and an older, still-open account with a small residual balance is forgotten.

The rules don't change with the broker. Shares held through a non-US custodian or investment bank — not just Fidelity, Schwab, E*TRADE or Morgan Stanley — are disclosed the same way if you're an ROR. Some of these brokers don't offer a clean CSV export the way US brokers do, so you may need to build the Table A2/A3 figures manually from account statements — the values required (peak, closing, initial value, acquisition date) are the same regardless of source.
Multiple accounts, one filing — ITRFA.in handles multiple Table A2 rows in a single upload session. Generate your Schedule FA →

FAQ

No. Only ROR taxpayers file Schedule FA. NRI and RNOR do not disclose foreign assets there.

Depends on your status for that year. ROR → yes, disclose US RSUs/ESPP/Fidelity. RNOR (common in the return year) → not required. Confirm your day count.

Yes. As an ROR you disclose the asset itself, income or not.

Yes. Every foreign asset is disclosed as an ROR, not just your RSU/ESPP brokerage account — a foreign bank account gets its own Schedule FA entry.

No — one consolidated Schedule FA with a Table A2 row per account and Table A3 rows for each account's holdings, all in the same ITR.
ROR with US stock? Generate Schedule FA in 2 minutes

Upload your Fidelity CSVs. ITRFA.in computes Table A2, A3, F with correct SBI TTBR rates and exports ITR-ready JSON + Excel.

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Related guides

Informational only, based on current law (FY 2025-26 / AY 2026-27). Residency rules are summarised; consult a chartered accountant to confirm your status.