If you returned from the US with RSU shares, it is easy to 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 (Resident but 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. Check your RNOR status and its tax benefits before assuming Schedule FA applies to you this year.
If you were in India for 182 days or more in FY 2025-26, you are ROR for that year when both of these conditions are met: you were resident in India in at least two of the ten previous years, and you spent 730 days or more in India across the seven previous years. If you miss either condition, you are RNOR for the year. 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: 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 are not part of this return's Schedule FA, even though those months fall inside FY 2025-26.
Schedule FA is part of ITR-2, the return form for individuals without business or professional income. ITR-1 and ITR-4 do not contain Schedule FA, so you cannot use them if you hold foreign assets.
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 RSUs are taxed in India and 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 an easy error to make in Schedule FA. Schedule FA has ten tables in all (A1 to A4 and B to G); for RSUs held in an equity plan account, A2 and A3 are the ones that apply.
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 depository 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
Schedule FA values are reported in Indian rupees, converted from USD. The ITR instructions prescribe the TTBR (Telegraphic Transfer Buying Rate), the rate State Bank of India adopts for buying a foreign currency received through telegraphic transfer. Use the SBI USD TT buying rate, not the TT selling rate, a card rate, or an online converter.
Use these dates for each field:
- Initial value: TTBR on the date of investment, which for RSU shares is the vesting date, even if that date was before 2025
- Peak value: TTBR on the date the peak value or peak balance occurred during calendar year 2025
- Closing value: TTBR on December 31, 2025
Example (illustrative figures): Priya holds 80 shares of Alphabet Inc., all vested before calendar year 2025 started. Assume the shares close at $170 per share on December 31, 2025 and 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 and its country code as listed in the form
- Name of financial institution: The broker's full legal name as shown on your account statement
- Address and zip code: Use the broker's registered address from your account statement
- Account number: Your equity plan account number
- Status: Your ownership status in the account (owner, beneficial owner, or beneficiary). If you are both the legal owner and the beneficial owner, as with an equity plan account in your own name, the ITR instructions say to report the legal owner status
- Account opening date: The date your equity plan account was set up
- Peak balance during the period: Highest account balance at any point during calendar year 2025, in INR at the TTBR on the date of the peak
- Closing balance: Account balance on December 31, 2025, in INR at the TTBR on that date
- Gross amount paid/credited to the account: The total credited to the account during calendar year 2025, with its nature selected from the list (interest, dividend, proceeds from sale or redemption of financial assets, or other income). For an equity plan account this typically includes dividends and the proceeds of any shares you sold
Table A2 has no initial value field. Use your 2025 account statements to work out the peak and closing balances and the amounts credited during the year.
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 and its country code as listed in the form
- 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 and ZIP code: The company's principal registered address, found on its website or annual report.
- Nature of entity: The type of entity whose shares you hold, for example a company.
- Date of acquiring the interest: The vesting date of the shares. For shares that vested before 2025, this is still the original vesting date, not January 1, 2025.
- Initial value of the investment: The value of the shares when you acquired them. For RSU shares, this is generally the market value on the vesting date, converted at the TTBR on that date.
- Peak value of investment during the period: Highest value of the holding at any point during calendar year 2025, converted at the TTBR on that date.
- Closing value: Shares × closing price on December 31, 2025 × TTBR on December 31, 2025. Enter zero if you sold all shares.
- Total gross amount paid/credited with respect to the holding: Dividends paid on these shares during calendar year 2025, in INR.
- Total gross proceeds from sale or redemption: If you sold shares, the total INR proceeds from all sales during calendar year 2025.
Each A3 row takes one date of acquisition and one initial value. If your shares in the same company came from several vesting lots, reporting each lot in its own row keeps both fields accurate for every lot.
Step 6: Report dividends and sale proceeds
Dividends and sale proceeds do not go in a separate table. They go in the income columns of the two tables you have already filled.
- Table A3: dividends go in the column for the total gross amount paid or credited with respect to the holding, and sale proceeds go in the column for gross proceeds from sale or redemption.
- Table A2: the same dividends and sale proceeds, as amounts credited to the account, each marked with its nature (dividend, or proceeds from sale or redemption of financial assets).
Table G is only for foreign income not covered in Tables A1 to F, so dividends already shown in A2 and A3 do not belong there.
Schedule FA is a disclosure. The income itself still has to be offered to tax under the relevant head of income in your return and, because it comes from outside India, reported in Schedule FSI as well.
RSU vesting income, the fair market value of the shares on the vesting date, is employment income. In the US it is taxed as wages at vesting and usually appears on your Form W-2. Where it is taxable in India, it goes under the salary head of your ITR and in Schedule FSI. Schedule FA's income columns are for what your holding earns, such as dividends, not for compensation at vesting.
If US taxes were withheld on your RSU income or dividends and you want to claim a foreign tax credit in India, file Form 67 on or before the end of the assessment year, which for FY 2025-26 is March 31, 2027, provided your ITR is filed within the time allowed under section 139(1) or 139(4) of the Income-tax Act, 1961 (Rule 128(9) of the Income-tax Rules, 1962). 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. The ITR instructions prescribe the SBI telegraphic transfer buying rate for Schedule FA. A bank transaction rate, card rate, or online converter rate does not meet that rule.
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. RNOR status ends once you meet both ROR conditions, so recheck your status every year. If you are ROR and leave a foreign asset out of your return, or report it inaccurately, the Assessing Officer can levy a penalty of Rs 10 lakh under Section 43 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015. From October 1, 2024, this penalty does not apply where your foreign assets other than immovable property total Rs 20 lakh or less in aggregate value, but the Schedule FA disclosure is still required. See Section 43 on the Income Tax India website for the full text.
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 reported in rupees at the SBI TTBR on the relevant dates. The reporting period is calendar year 2025 (January 1 to December 31), not the Indian financial year.
The errors to watch for are missing A2, reporting unvested shares, using January 1, 2025 in place of the actual vesting date, 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, note the SBI TTBR for each date you need, and work through the fields systematically.
Frequently asked questions
Is Schedule FA applicable to NRIs?
No. Schedule FA is mandatory only for Resident and Ordinarily Resident (ROR) taxpayers. If you are an NRI, you do not need to fill Schedule FA.
The obligation begins in the first financial year you cross the ROR threshold under Indian tax law. Your residential status is determined by counting the number of days spent in India during the current financial year and across the preceding years.
If you do not qualify as resident in India for a financial year, you remain an NRI for that year and Schedule FA does not apply.
Do I need to report unvested RSUs in Schedule FA?
No. Unvested RSUs are a future entitlement, not an asset you currently own. Schedule FA covers foreign assets you hold, and unvested RSUs do not qualify. The reporting trigger is the vesting date, when the shares transfer to your equity plan brokerage account. The grant date only determines the schedule; it is not when ownership begins.
How do I find the correct SBI TTBR rate?
Use the telegraphic transfer buying rate (TTBR) that State Bank of India adopted for USD on the date in question. You need the TT buying rate specifically, not the TT selling rate, a card rate, or an online converter. The ITR instructions tie each value to a date: the date of investment for the initial value (for RSU shares, the vesting date), the date of the peak for the peak value, and December 31, 2025 for the closing value.
What is the initial value of investment in Schedule FA for RSU shares?
It is the value of the shares when you acquired them, converted to rupees at the SBI TTBR on that date. For RSU shares, the acquisition date is the vesting date and the value is generally the market value of the shares on that day. It is not the value on January 1 of the reporting year, even if the shares vested years earlier.