Who Must File Schedule FA? ROR vs RNOR vs NRI

5 min read · Updated June 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.

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.

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.
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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.