Schedule FA and crypto on foreign exchanges
By BtcMedia Research · Updated · Rules checked 22 Oct 2026
Key takeaways
- Resident (ROR) taxpayers must disclose all foreign assets and accounts in Schedule FA of ITR-2/ITR-3.
- It covers the calendar year (1 Jan–31 Dec), and anything held at any time in it.
- There is no crypto row and no official ruling on offshore exchange balances; disclosure is the cautious course.
- Non-disclosure can cost ₹10 lakh under the Black Money Act; not applied if non-immovable foreign assets total ₹20 lakh or less (from 1 Oct 2024).
Many Indians hold crypto on exchanges based outside India. Selling or swapping it is reported in Schedule VDA and taxed at 30% like any other crypto. But a balance sitting on a foreign platform raises a second question: is it a foreign asset that must be disclosed in Schedule FA? Here is what the official instructions say, and where the grey area is.
Who must fill Schedule FA
According to the Income Tax Department's step-by-step guide, residents must disclose every foreign asset or account of which they are the legal owner, beneficial owner or beneficiary. People who are "not ordinarily resident" or non-resident for the year do not need to fill it. Schedule FA is in ITR-2 and ITR-3, so you cannot use ITR-1 if you have foreign assets to report. Assets reported in Schedule FA must also go in Schedule AL if that schedule applies to you.
The calendar-year rule
Unlike the rest of the return, Schedule FA uses the calendar year ending 31 December. Report every foreign asset held at any time during that period, including accounts closed during it. Values are converted to rupees at the SBI telegraphic transfer buying rate on the relevant date (peak balance date, investment date, or 31 December).
The tables
| Table A1 | Foreign depository accounts (peak and closing balance, interest) |
| Table A2 | Foreign custodian accounts (peak and closing balance, amounts credited) |
| Table A3 | Foreign equity and debt interest |
| Table A4 | Foreign cash-value insurance or annuity contracts |
| Table B | Financial interest in any entity outside India |
| Table C | Immovable property outside India |
| Table D | Other capital assets outside India |
| Table E | Foreign accounts with signing authority not reported in A1–D |
| Table F | Trusts created outside India |
| Table G | Other income from sources outside India |
Where does crypto fit?
Nowhere explicitly. The schedule has no crypto or VDA row, and we found no CBDT clarification or court ruling on whether a balance on an offshore exchange, or in a self-custody wallet, is an asset "located outside India". Practitioners who advise disclosure usually report an offshore exchange balance as a foreign custodial account (Table A2: peak and closing balance), or as another capital asset outside India (Table D). A self-custody wallet has no location in the usual sense, which makes the position even less clear.
The asymmetry matters. Disclosing a balance costs you some paperwork; omitting a foreign asset that should have been disclosed can attract a flat ₹10 lakh penalty. Take advice from a chartered accountant and keep exchange statements showing your peak and 31 December balances.
Penalties
Sections 42 and 43 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 provide a ₹10 lakh penalty for a resident who fails to file a return, or files one without disclosing a foreign asset or foreign income (or with inaccurate details). A proviso inserted with effect from 1 October 2024 says these penalties do not apply where the aggregate value of the assets, other than immovable property, does not exceed ₹20 lakh. That relief covers only these penalties; it does not remove the duty to disclose, or the tax and penalties on undisclosed foreign income or assets.
The Income Tax Department also receives information on foreign financial accounts under the CRS and FATCA exchange programmes, as its note on Schedule FA explains, and FIU-IND-registered exchanges, including offshore ones such as Binance and KuCoin, have reporting duties in India.
FAQ
Do I need to report crypto on Binance or another foreign exchange in Schedule FA?
Schedule FA asks residents to disclose all foreign assets and accounts they own or benefit from. It has no row for crypto, and there is no official ruling on whether a balance on an offshore exchange is a "foreign asset". Because the penalty for leaving out a foreign asset can be ₹10 lakh, many practitioners advise disclosing such balances, typically as a foreign custodial account (Table A2) or another capital asset (Table D). Decide with a chartered accountant.
Which period does Schedule FA cover?
The calendar year ending 31 December within the previous year, not the April–March financial year. For example, for AY 2025-26 it was 1 January to 31 December 2024. Report anything held at any time in that period, even if it was closed or sold before the year end.
Who has to fill Schedule FA?
Residents and ordinarily residents (ROR). If you are "not ordinarily resident" or non-resident for the year, you do not need to fill it. Schedule FA is part of ITR-2 and ITR-3, so someone with foreign assets cannot use ITR-1.
What is the penalty for not reporting foreign assets?
Under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015, failure to disclose a foreign asset can attract a ₹10 lakh penalty (sections 42 and 43). Since 1 October 2024 this does not apply where the total value of the assets other than immovable property does not exceed ₹20 lakh. Undisclosed foreign income and assets can also be taxed and penalised separately under that Act.
Is this the same as Schedule VDA?
No. Schedule VDA reports each sale or swap of crypto and the gain taxed at 30%. Schedule FA reports holdings abroad. A trade on a foreign exchange can need both.
What exchange rate do I use?
The State Bank of India telegraphic transfer buying rate on the relevant date: the date of the peak balance, the date of investment, or 31 December.
Sources
- Income Tax Department: Step-by-step guide to fill Schedules FSI, TR and FA (March 2026)
- Income Tax Department: Note on Schedule FA/FSI, CRS and FATCA
- Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 (India Code), sections 42–43
- Income Tax Department: Taxation of VDAs
- Lok Sabha USQ 5805: FIU-IND registered VDA service providers
Not tax advice. Where the law is unsettled we say so. Confirm your filing position with a chartered accountant.
More: Schedule VDA filing guide · gift, airdrop & staking tax · exchanges and FIU-IND status · all guides
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- Guide published. Sources: Income Tax Department Schedule FA guide (Mar 2026) and CRS/FATCA note, Black Money Act ss.42-43.