Foreign Assets · NRI Tax · Voluntary Disclosure · FY 2026-27

Had a Foreign Bank Account or Shares and Never Reported It? Here's Your One-Time Fix.

A simple guide to India’s one-time disclosure option for unreported foreign bank accounts and shares, including who can use it and how to correct past non-disclosure.

R CA Rishabh GoyalCA · Founder, TaxSavvy 📅 ⏱ 🔄

TL;DR — The 60-second version

You studied abroad and had a foreign bank account. Or you're an NRI who came back to India and never reported an overseas investment. Or you have RSUs/ESPPs from your employer but didn't disclose them. You know the asset exists, but it was never reported in an ITR. You're worried about penalties or prosecution. FAST-DS 2026 gives you a 6-month window to disclose it, pay a one-time fee or tax amount, and get immunity — but only if you act before the window closes.

Collect all your foreign-asset documents: bank statements, brokerage records, tax returns, purchase proofs, ESOP/RSU statements. Determine your residential status when the asset was acquired. Identify which disclosure route applies (undisclosed income, or taxed income but unreported asset). Calculate the payment amount. File the disclosure within the 6-month window. Get immunity from past penalties and prosecution.

We review your foreign-asset history, confirm eligibility under FAST-DS, calculate the disclosure payment, prepare the formal declaration, and file it within the deadline. Talk to a TaxSavvy CA with cross-border tax experience before the window closes.

Stage 01Fact of the Case

Arjun studied in the US for 5 years and maintained a foreign bank account with savings of $12,000 (roughly Rs. 10 lakhs). After returning to India as a resident, he never disclosed this account in his ITRs because he thought overseas personal savings didn't need reporting. Now, in 2026, he's heard about FAST-DS — a scheme that allows him to disclose the foreign account and get immunity from penalties. But he's unsure: Does the scheme apply to him? How much will he need to pay? What documents does he need? If he doesn't disclose, what's the risk? He needs clarity on whether FAST-DS can resolve his foreign-asset compliance issue.

Stage 02Applicable Laws & Provisions

Finance Act, 2026 — FAST-DS Foreign Assets of Small Taxpayers Disclosure Scheme, 2026

FAST-DS is a one-time voluntary disclosure scheme for specified past non-disclosures of foreign income or overseas assets. Eligible taxpayers who make a valid declaration and pay the prescribed amount receive immunity from further tax, penalties, and prosecution under the Black Money Act for the disclosed item, subject to scheme conditions.

Schedule FA, Schedule FSI Foreign Assets and Foreign-Source Income Schedules

Taxpayers with foreign assets or foreign-source income must use ITR forms that include Schedule FA (foreign assets) and Schedule FSI (foreign-source income). ITR-1 and ITR-4 do not include these schedules and cannot be used. Using the wrong ITR form when foreign assets exist is itself a compliance error.

Black Money Act, 2015 — Immunity Provision Amnesty from Prosecution and Penalties

A valid FAST-DS declaration provides immunity from prosecution and penalties under the Black Money Act for the disclosed foreign income or asset. This protection applies only to the amount declared and only if all scheme conditions are met. Future foreign assets or income are not covered by the immunity.

Stage 03Mapping Laws to the Case

Here's who qualifies for FAST-DS, which route applies, and what can go wrong if you don't declare.

Fact	Section	Impact	Action
You had a foreign bank account abroad but never disclosed it	Schedule FA	Non-disclosure risk — back-tax demand, penalties, prosecution under Black Money Act	Use FAST-DS Route 1 to disclose; pay ~60% of value as tax; get immunity from penalties
You earned foreign income and taxed it, but didn't report the resulting asset	Schedule FSI	Partial disclosure creates compliance gap — penalties still possible	Use FAST-DS Route 2; pay Rs. 1 lakh fee; asset gets reported and compliant
You hold RSUs/ESPPs from your employer but never disclosed them in ITR	Schedule FA	Foreign asset not reported — blacklisted if discovered later	Calculate fair value of RSUs/ESPPs, disclose under FAST-DS Route 1, pay prescribed amount
You file ITR-1 or ITR-4 without disclosing foreign account	Schedule FA	Wrong ITR form + missing Schedule FA = compounded error	Switch to correct form with Schedule FA; if disclosing, file under FAST-DS simultaneously
You miss the 6-month FAST-DS window and don't disclose	Section 271AAF + Black Money Act	Late disclosure loses immunity; face full penalties + prosecution risk	File within 6-month window from notification date — don't delay
You disclose but don't pay the prescribed amount by due date	FAST-DS scheme conditions	Declaration deemed incomplete; immunity not granted	Pay the full amount (Route 1: ~60% of value; Route 2: Rs. 1 lakh) within deadline

⚠️ Additional risk found during mapping

⚠️ The 6-month FAST-DS window is one-time only. Once it closes, you lose the opportunity to get immunity from penalties and prosecution. If discovered later without disclosure, you face full back-tax, penalties (50-100% of tax), and potential criminal prosecution under the Black Money Act. The scheme is your amnesty — use it before the deadline.

Stage 04Conclusion

✅ Action Plan — in order

01 Confirm the official FAST-DS commencement date before taking any action. The Finance Act 2026 introduced FAST-DS, but the scheme's 6-month window starts only from the date the Central Government officially notifies. Check the Income Tax Department's official website (incometaxindia.gov.in) for the notification. Don't assume the window is open yet or rely on rumors. Once notified, note the exact start date — your 6-month deadline is 180 days from that date. Deadline: Check before you collect documents.

02 Collect all foreign-asset documents from inception, not just recent statements. Gather: foreign bank statements (all years the account existed), brokerage records, ESOP/ESPP/RSU grant letters and valuations, overseas tax returns, proof of income earned abroad, purchase documents for overseas property, retirement account statements (401k, RRSP, etc.), proof of funds transfer (how you got the money abroad), current valuation of all foreign assets. Don't cherry-pick recent years — if the account existed 10 years ago, collect documents from then. The disclosure is only credible if backed by contemporaneous proof. Deadline: Within 1 month of FAST-DS notification.

03 Determine your residential status in India when the foreign asset was acquired or income arose. Were you a resident of India, non-resident (NR), or not ordinarily resident (NOR) at the time the foreign bank account was opened, the overseas shares were bought, or the foreign income was earned? Your residential status matters for FAST-DS eligibility. You'll need: passport, visa stamps, PAN registration date, employment records, proof of when you moved abroad or returned to India. This information determines whether FAST-DS applies to you and which route is available. Ask your CA to confirm your status for the relevant year. Deadline: Within 2 months of notification.

04 Identify whether the foreign asset/income is disclosed or undisclosed — choose your route. Route 1: Foreign income or asset was NEVER reported in any ITR. Value limit: Rs. 1 crore. Payment: ~60% of the asset value or income as tax. Route 2: Foreign income WAS reported or taxed, but the asset acquired from it was NOT reported in the ITR's Schedule FA. Value limit: Rs. 5 crores. Payment: Fixed Rs. 1 lakh fee. These are different. A disclosure of income is not the same as disclosure of the asset purchased from it. Look at your past ITRs carefully. Did you report the income? Did you report the asset? The gap determines your route. Deadline: Within 2 months.

05 Calculate the prescribed payment amount for your disclosure. Route 1: The amount is 30% tax on the asset value or income, plus 100% additional tax = approximately 60% of the value. Example: Undisclosed foreign bank account with balance Rs. 10 lakhs. Payment = Rs. 6 lakhs (60% of Rs. 10 lakhs). Route 2: Fixed fee of Rs. 1 lakh, regardless of asset value. Your CA should do this calculation. Once calculated, confirm you have the funds to pay before filing. The disclosure loses value if you can't pay the amount within the deadline. Deadline: Within 3 months of notification.

06 File ITR using the correct form with Schedule FA and Schedule FSI, not ITR-1 or ITR-4. Do not use ITR-1 or ITR-4 if you have foreign assets — these forms lack Schedule FA. Use a form that includes Schedule FA (foreign assets), Schedule FSI (foreign-source income), and Schedule TR (if claiming foreign-tax relief). File your ITR within the normal deadline, reporting the foreign asset in the correct schedule. This ITR becomes the formal record supporting your FAST-DS disclosure. Your CA will prepare this ITR separately from the FAST-DS declaration. Deadline: By normal ITR due date (usually July 31 or extended date).

07 Prepare the formal FAST-DS declaration with all supporting documents. The Central Government will release a prescribed form and process once FAST-DS is notified. Your declaration must include : description of the foreign asset or income, acquisition date, current valuation, reason for non-disclosure (oversight, complexity, lack of awareness), proof of funds, all supporting documents collected in Step 2, calculation of the payment amount, and proof of tax residency. Hire a tax professional with cross-border experience to prepare this. Errors or omissions in the declaration can disqualify you from immunity. This is not a DIY task. Deadline: Within 5 months of notification.

08 Pay the prescribed FAST-DS amount through the official income tax payment channel. Once your declaration is ready and you've confirmed the payment amount, pay it through the official income tax website, bank, or authorized payment portal. Get a challan/receipt with reference number. Do not pay into a personal account or through unauthorized channels — the payment must be officially recorded against your PAN. Keep the payment proof with your declaration documents. Payment must be made before the declaration is filed, or within a deadline specified by the scheme. Deadline: By the deadline specified in the FAST-DS notification (likely 6 months from start).

09 Pay the prescribed FAST-DS amount through the official income tax payment channel. Once your declaration is ready and you've confirmed the payment amount, pay it through the official income tax website, bank, or authorized payment portal. Get a challan/receipt with reference number. Do not pay into a personal account or through unauthorized channels — the payment must be officially recorded against your PAN. Keep the payment proof with your declaration documents. Payment must be made before the declaration is filed, or within a deadline specified by the scheme. Deadline: By the deadline specified in the FAST-DS notification (likely 6 months from start).

10 After disclosure, maintain compliant foreign-asset reporting in future ITRs. Once your past foreign asset is disclosed and regularized under FAST-DS, you're protected from penalties and prosecution for that item. But any new foreign assets or foreign income acquired after the declaration must be reported in your regular ITRs using Schedule FA and Schedule FSI. The immunity is only for the disclosed item — not for future non-compliance. Going forward, report foreign assets every year in your ITR. Don't assume the scheme covers everything. Deadline: Ongoing, starting next ITR filing.

Foreign assets are not optional reporting — they're mandatory for tax compliance in India. FAST-DS 2026 is a rare, one-time opportunity to correct past mistakes without facing prosecution or heavy penalties. But it's not open forever. The 6-month window is your chance to turn a compliance gap into a clean record. Collect your documents, understand which route applies, calculate the payment, and file the declaration before the deadline. Waiting for a notice from the department before acting is far more expensive and stressful than disclosing now. The scheme is your amnesty — use it.

Held an overseas account or foreign shares but never reported them?

CA Rishabh will handle this for you

Assess FAST-DS eligibility • Determine disclosure route (1 or 2) • Calculate payment amount • Prepare and file declaration

💬 WhatsApp Rishabh's team →