Schedule FA Filing for US RSUs: Step-by-Step (with Examples)
The exact rows, the exact rupee figures, the exact dates — Schedule FA filling for Indian residents holding RSUs from US tech employers, walked through line by line.
The disclosure, not the tax
Schedule FA is the part of your Indian Income Tax Return where you disclose every foreign asset you hold — bank accounts, equity, debt, property, even foreign signing authority on someone else's account.
It is not a tax computation. You do not pay Schedule FA tax. You disclose, and the IT Department reconciles your disclosure against the data they already receive from US financial institutions under the Common Reporting Standard (CRS) — end-of-year balances at Schwab, Fidelity, Morgan Stanley, etc. all get fed to Indian tax authorities automatically. A mismatch between what you disclose and what they already know is the most common trigger for a Section 148 reassessment notice.
We covered why Schedule FA matters in the RSU Taxation pillar. This guide is the mechanical how — table by table, column by column, with worked rupee examples for one Bengaluru-based Google engineer carrying six years of vests.
1. Where Schedule FA lives in your ITR
Schedule FA appears in ITR-2 and ITR-3 — the forms used by salaried individuals with capital gains or business income. ITR-1 (Sahaj) does not contain Schedule FA, which means if you hold foreign assets, you cannot use ITR-1 even if your total income otherwise qualifies. Filing ITR-1 while holding foreign equity is itself a defective filing.
The schedule is divided into seven tables:
For a typical RSU holder at a US tech company, you will fill A2 (the brokerage account itself) and A3 (each equity position inside it). Everything else is usually blank.
2. Table A2 — your brokerage account
Table A2 reports the account that holds your foreign equity, not the equity itself. Schwab Equity Awards, Morgan Stanley StockPlan, E*TRADE Stock Plans, Fidelity Stock Plan Services — all custodial accounts under SEC custody rules. One row per account.
Columns in Table A2
The peak balance is the trip-up. It is not your peak share price — it is the peak INR account value, which includes cash sweep and any uninvested proceeds from sales. If you sold a tranche in October and the cash sat in the account for two weeks before you remitted, that combined cash + remaining shares position can be your peak.
3. Table A3 — each RSU lot, individually
This is where most engineers spend the most time, because each vest gets its own row. Twenty-four quarterly vests over six years = twenty-four rows. ESPP semi-annual purchases over the same period = another twelve rows. It adds up fast.
Columns in Table A3
4. Worked example — Priya's Schedule FA for AY 2026-27
Same Priya from the RSU Taxation pillar: Senior Software Engineer at Google Bengaluru, ₹85L base, 1,000 GOOGL granted in 2022 vesting quarterly over four years.
For her ITR for FY 2025-26 (filed July 2026), her Schedule FA accounting period is Jan 1, 2025 – Dec 31, 2025. As of Dec 31, 2025 she held GOOGL from sixteen quarterly vests, having sold three small lots earlier in the year.
Step 1 — Inventory the lots
Pull the broker's end-of-year statement (Schwab Equity Awards Year-End Tax Information). For each lot held at any point during Jan 1–Dec 31, 2025:
- Vest date
- Number of shares
- USD price on vest day (closing price)
- RBI TT buying rate on vest day
- Whether the lot was sold during 2025 (and the sale price/date if so)
Step 2 — Compute INR values per lot
For each lot, four numbers:
- Initial value = shares × USD vest price × RBI TT rate on vest day
- Peak value = highest (USD market price × RBI rate) × shares over Jan 1–Dec 31. Strictly, this is computed daily and the maximum is taken. Pragmatically: month-end values are often used as a defensible approximation.
- Closing value = shares × USD price on Dec 31, 2025 × RBI rate on Dec 31, 2025. (If the lot was sold before Dec 31, closing value is 0.)
- Sale proceeds = if sold during 2025, INR proceeds at sale-day rate
Step 3 — One row in A3 per lot
Below is what three of Priya's sixteen GOOGL lots look like — abridged from a real Schedule FA submission (USD figures rounded for clarity):
Notice the peak and closing values are the same across all three rows — that is because peak and closing apply to the position of that lot on those dates, which depends only on the share count and the market price. The initial value differs across rows because the cost basis was locked at the vest day's INR rate.
Priya's full Schedule FA submission for AY 2026-27 contains sixteen rows in A3 (one per held lot), one row in A2 (her Schwab account), and nothing else. Total time, computed manually with the broker statement and RBI's historical TT rates page: ~5 hours her first year, ~3 hours each year after as her template stabilized.
5. Six mistakes that get filings flagged
Mistake 1 — Using financial year instead of calendar year. Filers populate A3 with assets held between April 1 and March 31. Wrong. Schedule FA uses Jan 1–Dec 31. Acquisition dates are calendar-real, but the “during the accounting period” window is calendar-year.
Mistake 2 — Reporting only Dec 31 holdings. If you held a position from January 1 to October 1 and then sold, you must still report that lot — with peak value during your holding period and sale proceeds. Many filers omit sold-during-the-year lots; this is non-disclosure.
Mistake 3 — Using broker's USD figures directly. Schedule FA requires INR. Filers paste USD amounts thinking the IT Department will figure it out — they will not, and the recomputation defaults to the broker's spot rate, which is rarely the RBI TT rate.
Mistake 4 — One row for all RSUs of one ticker. A common shortcut: aggregating all 24 GOOGL vests into a single A3 row with summed values. This is technically a defective filing — each “interest” (each acquisition event) requires its own row. The aggregation makes peak/closing math impossible to audit.
Mistake 5 — Forgetting Table A2. Filers fill A3 (equity) but skip A2 (the account). Strictly, the custodial account itself is a disclosable interest separate from the underlying equity. Conservative practice fills both.
Mistake 6 — Treating sold lots as “gone.” If a lot was sold during 2025, you still report it in Schedule FA for AY 2026-27 — with sale proceeds populated. Schedule FA is about any holding during the period, not just year-end holdings.
6. What missing Schedule FA actually costs
The RSU Taxation pillar covered the penalty stack briefly. The full picture, specifically for Schedule FA non-disclosure under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015:
- Section 43: ₹10 lakh per year of non-disclosure. A five-year history of non-filing = ₹50L of accrued penalty exposure.
- Section 41: If undisclosed foreign income is traced (e.g., RSU vest perquisite not declared), 30% tax + 90% penalty + 30% interest from the year of accrual.
- Section 50: Willful failure to furnish required information about foreign assets — imprisonment from 6 months to 7 years, plus fine.
- Reassessment without time limit: Section 149(1)(c) of the Income Tax Act allows reopening of assessment up to 10 years for undisclosed foreign assets, versus the normal 4-year limit.
In practice, the IT Department now receives end-of-year balances at US financial institutions via the Common Reporting Standard. As of FY 2023-24, AIS (Annual Information Statement) shows pre-populated foreign asset data for many filers. The argument “they will not find out” is no longer operational.
7. What Rovia does
For most engineers, Schedule FA is a five-hour July ritual: rebuild a spreadsheet of every vest, look up the RBI rate on each vest day from the historical reference page, compute initial values, look up market closes and FX rates for peak and closing computation, transcribe into the ITR-2 form.
Rovia removes the spreadsheet:
- Broker statement ingestion. Schwab Equity Awards, Morgan Stanley StockPlan, E*TRADE, Fidelity — directly. Each lot is identified by vest date and share count.
- RBI TT rate per date. The full RBI historical reference rate database is applied automatically. No copy-paste from rbi.org.in.
- Per-lot peak computation. Daily closing prices for each held position over Jan 1–Dec 31 are valued in INR using the daily TT rate, and the per-lot maximum is computed. Defensible to audit.
- Output: ITR-2 Schedule FA in the exact column format. Tables A2 and A3 pre-filled. Copy-paste into the ITR portal or hand to your CA.
- Multi-year history. If you have never filed Schedule FA, the platform can reconstruct prior-year disclosures so you can do a compounded-disclosure under Section 139(8A) updated-return route — the cleaner path than waiting for a notice.
Frequently asked questions
I never sold anything. Do I still file Schedule FA?
Yes. Schedule FA is a holding disclosure, not an income disclosure. If you held any vested RSU shares at any point during the calendar-year accounting period (Jan 1 to Dec 31), you must report them — even if you never sold, never received a dividend, never moved a rupee.
I sold everything in December. Do I still file?
Yes. The filing requirement is based on whether you held the asset at any point during the accounting period, not on what you held at year-end. A position you held for one day in January and sold the same day must be disclosed.
My RSUs sit in Schwab. Do I file under Table A1 (Depository), A2 (Custodial), or A3 (Equity)?
For most US employers, the brokerage account is custodial — A2 covers the account itself, A3 covers each individual equity position inside it. Schwab Equity Awards, Morgan Stanley StockPlan, E*TRADE: all custodial. So you may end up filling both A2 (for the account) and A3 (for the underlying shares). Some accountants take a pragmatic view and only fill A3 for foreign equity; the strictly-correct read is to fill both.
What if I have 24 quarterly vest lots? Do I report 24 rows in A3?
Yes. Each "interest" — each acquisition of foreign equity — needs its own row. Twenty-four quarterly vests over six years means twenty-four rows in Table A3, each with its own acquisition date, initial value, peak value, and closing value. This is the part that takes Indian engineers 4–6 hours of manual reconciliation.
My RSUs vested in USD. How do I convert to INR for Schedule FA?
For acquisition value: USD price on vest day × RBI TT buying rate on vest day. For peak value: this is the hardest one — strictly, you compute INR value of your shareholding daily across Jan 1–Dec 31 (USD market price × RBI rate that day) and take the maximum. In practice many filers use month-end values and pick the peak month; this is defensible but imperfect. For closing value: USD price on Dec 31 × RBI rate on Dec 31.
What is the penalty if I miss Schedule FA?
₹10 lakh per year of non-disclosure under Section 43 of the Black Money Act. Prosecution risk under Section 50. The penalty is per year, not per asset — so a five-year gap of non-filing carries ~₹50L of penalty exposure plus interest. The IT Department now receives end-of-year balances from US institutions via CRS, so non-filing is increasingly mechanically detectable.
Last reviewed June 1, 2026. Rules quoted reflect ITR-2/3 Schedule FA structure for AY 2026-27 and the Black Money Act, 2015. This article is informational and not personalised tax advice — your specific position should be reviewed by a qualified chartered accountant.