How to declare RSU shares in Schedule FA while filing your ITR

Most people who returned from the US with RSU shares fill only Table A3 in Schedule FA and call it done. That leaves the brokerage account holding those shares undisclosed, which is an incomplete filing. Both Table A2 and A3 are required, and this guide covers exactly how to fill each one.

I'll walk you through the field-by-field entries for both tables, how to convert share values to INR using SBI TTBR, and what to do if you sold your shares before December 31. If you need a broader overview of all the schedules ROR taxpayers must file, the Schedule FA, FSI, TR, and Form 10F guide covers the full picture.

Who needs to file Schedule FA

Schedule FA is mandatory only for taxpayers classified as Resident and Ordinarily Resident (ROR) in India.

If you are still in the RNOR (Not Ordinarily Resident) period, you are exempt from Schedule FA for that year. Many people who returned to India in the last two or three years still qualify as RNOR and do not know it. Check your RNOR status and its tax benefits before assuming Schedule FA applies to you this year.

If you returned before FY 2022-23 and have spent 182 days or more in India in the years since, you are almost certainly ROR for FY 2025-26. As an ROR, you must report any foreign asset you held at any point during calendar year 2025, that is, January 1, 2025 to December 31, 2025.

One important distinction most guides miss: Schedule FA does not follow the Indian financial year (April to March). It uses the calendar year (January to December) as its accounting period. So even though your ITR is for FY 2025-26, the Schedule FA section covers January 1, 2025 to December 31, 2025 only. RSU shares that vested or were held only between January 1, 2026 and March 31, 2026 will be reported in Schedule FA for AY 2027-28, not this return.

Step 1: Confirm which RSUs qualify for reporting

The rule is clear: report vested RSUs. Until shares vest, you do not own them and they do not belong in Schedule FA.

Report the following:

• RSU shares that vested at any point during calendar year 2025 and that you still hold on December 31, 2025.
• RSU shares that vested in a prior calendar year and that you continue to hold.
• RSU shares that vested during calendar year 2025 and were sold before December 31, 2025. These go in with a zero closing balance, and the sale proceeds are filled in separately.

Do not report unvested RSUs. They are future compensation that the company still controls. The reporting trigger is the vesting date, not the grant date.

The India-side tax treatment of RSU vesting income and the capital gains tax when you sell is a separate topic, covered in our guide on how RSU income is taxed in the US. That is about the tax you owe. Schedule FA is about the asset you hold.

Step 2: Identify the two tables you need to fill

If your RSUs are held through a company equity plan administered by a broker, you need two entries in Schedule FA, not one.

Table A2: the custodial brokerage account

When RSUs vest, the shares land in a brokerage account set up by your employer's equity plan administrator. Common administrators are E*Trade Financial Services, Fidelity Stock Plan Services, Morgan Stanley at Work, and Schwab Equity Award Center.

That brokerage account is a foreign custodial account. It goes into Table A2 of Schedule FA.

Table A3: the RSU shares themselves

The shares you own inside that account go into Table A3, which covers foreign equity and debt interests. This is where you declare your stake in the company that granted you the RSUs.

You fill A2 for the account and A3 for the shares. Filling only A3 and missing A2 is the most common error RSU holders make in Schedule FA.

If you also have a personal US brokerage account (a self-directed account at Schwab, Robinhood, or similar) where you transferred RSU proceeds or bought additional stock, that account goes into A1 if it is a depositary account or A2 if it is a custodial account. Your broker statement will clarify the account type.

Step 3: Convert values to INR using SBI TTBR

All values in Schedule FA go in both USD and INR. The mandated exchange rate is the TTBR (Telegraphic Transfer Buying Rate) published daily by State Bank of India.

To find historical TTBR rates, go to the SBI website, navigate to the forex rates section, and look for the historical rate archive. Search for the USD-INR TTBR on the specific date you need.

Use these dates for each field:

• Initial value: TTBR on January 1, 2025 (or the date of your first vesting if later)
• Peak value: TTBR on the date the highest USD holding occurred during calendar year 2025
• Closing value: TTBR on December 31, 2025

Example: Priya holds 80 shares of Alphabet Inc., all vested before calendar year 2025 started. On December 31, 2025, the shares trade at $170 per share. The SBI TTBR on that date is Rs 85.50. Her closing value = 80 × $170 × Rs 85.50 = Rs 11,62,800.

Steps 4 and 5 below show exactly what to enter in each table, field by field.

Step 4: Fill Table A2

Open Schedule FA in the ITR portal and go to Table A2. Enter the following:

• Country name and code: United States, US
• Name of institution: Full legal name (E*Trade Financial Services Inc., Fidelity Brokerage Services LLC, etc.)
• Address and zip code: Use the broker's registered address from your account statement
• Account number: Your equity plan account number
• Status: Active if the account is still open; Closed if it was shut during calendar year 2025
• Account opening date: The date your equity plan account was set up
• Initial value: Account balance in USD and INR on January 1, 2025
• Peak balance: Highest account balance in USD and INR at any point during calendar year 2025
• Closing balance: Account balance in USD and INR on December 31, 2025
• Income derived: Any interest credited to the account (usually zero for equity plan accounts)

Your equity plan annual statement will have the opening, peak, and closing balances. Most brokers generate a year-end account summary in January or February.

Step 5: Fill Table A3 for your RSU shares in Schedule FA

Table A3 is the core of your Schedule FA RSU entry. Each company whose shares you hold gets its own A3 row. Enter the following:

• Country name and code: United States, US
• Name of entity: Full legal company name. Write "Alphabet Inc." not "Google." Check the company's investor relations page or SEC filings for the exact registered name.
• Address: The company's principal registered address, found on its website or annual report.
• ISIN: The 12-digit identifier for the stock. For US-listed stocks it starts with "US." Your broker statement or the equity plan portal shows the ISIN. For dual-listed companies, it is also available on the NSE or BSE listing pages.
• Nature of interest: Select "Beneficial Owner." After RSUs vest, you own the shares directly.
• Date of acquisition: The date of your first RSU lot vesting. If you held shares before calendar year 2025 started, use January 1, 2025 as the reporting start.
• Initial value: INR value of your total holding on January 1, 2025. Multiply shares held × price on January 1, 2025 × TTBR on January 1, 2025.
• Peak value: Highest INR value of your total holding at any point during calendar year 2025.
• Closing value: Shares × closing price on December 31, 2025 × TTBR on December 31, 2025. Enter zero if you sold all shares.
• Income derived: Dividends paid on your shares during calendar year 2025, in both USD and INR.
• Proceeds from sale: If you sold shares, the total INR proceeds from all sales during calendar year 2025.

If you received RSUs in multiple lots across different vesting dates but all from the same company, combine them into one A3 entry. Do not create a separate row for each vesting lot.

Step 6: Report income from foreign assets in Table A10

Table A10 captures income your foreign assets generated during the year.

For RSU holders, this mainly covers dividends. If the company paid a dividend while you held shares during calendar year 2025, report the USD amount and its INR equivalent here.

RSU vesting income, the fair market value of shares on the vesting date, is salary income. It is usually reported in your US W-2 and goes into Schedule FSI of your ITR, not into A10. A10 is for investment income from assets you continue to hold, not for compensation income at vesting.

If US taxes were withheld on your RSU income and you want to claim a credit in India to reduce double taxation, you need to file Form 67 before submitting your ITR. Our step-by-step guide to filing Form 67 covers that process in full.

Common mistakes to avoid

Filling only A3 and skipping A2. If your shares sit in a company equity plan account, both tables are required. A3 alone is an incomplete disclosure.

Reporting unvested RSUs. They are not yours yet. The grant date gives you the right to receive shares in the future. The vesting date is when you actually own them. Only report vested shares.

Using the wrong exchange rate. SBI TTBR is the only rate the ITR system recognises for this purpose. Using a bank transaction rate, card rate, or an online converter creates a mismatch when the tax department's systems cross-verify your filing.

Using March 31 instead of December 31. Schedule FA uses the calendar year, not the Indian financial year. The closing balance date is December 31, 2025, not March 31, 2026. Using the wrong date affects your INR values and the TTBR rate applied.

Not disclosing because you sold everything. If you held RSU shares at any point during calendar year 2025 and are ROR, you must report them. Enter a zero closing balance and fill in the sale proceeds. A sold position is not an exemption from disclosure.

Assuming you are still RNOR. If you returned to India before FY 2022-23, check your status carefully. Filing without Schedule FA as an ROR attracts a penalty of up to Rs 10 lakh per year under Section 43 of the Black Money Act. See the Income Tax India website for the full penalty provisions.

Conclusion

Declaring RSU shares in Schedule FA comes down to two entries: Table A2 for the custodial brokerage account and Table A3 for the shares, with all values in USD and INR using SBI TTBR on the relevant dates. The reporting period is calendar year 2025 (January 1 to December 31), not the Indian financial year.

The most frequent errors are missing A2, reporting unvested shares, using March 31 instead of December 31, and skipping the disclosure after a full sale. Once you are ROR, the Schedule FA RSU filing is not optional. Pull your equity plan year-end statement, check SBI's historical TTBR for each date you need, and work through the fields systematically.