The single most common Schedule FA mistake Indian RSU holders make

Schedule FA for AY 2026-27 covers assets you held at any point between January 1, 2025 and December 31, 2025. Not April 1, 2025 to March 31, 2026. Not the financial year. The calendar year.

That is the mistake. It is the single most common Schedule FA error, and it is almost universal among first-time filers. Every other schedule in ITR-2 runs on the Indian financial year — April to March. Schedule FA does not. The mismatch is not a typo. It is deliberate. And if you pull the wrong statements, you will file a disclosure that does not match what the Income Tax Department already knows about your account.

Why the period is a calendar year

Schedule FA was designed to align with the OECD's Automatic Exchange of Information framework — the Common Reporting Standard that now connects more than a hundred tax authorities. Under CRS, foreign financial institutions (US brokers like Charles Schwab, Fidelity, Morgan Stanley Shareworks) report data on Indian-resident account holders to the IRS, which then exchanges it with the Indian Income Tax Department. That data is structured on a calendar-year basis: January 1 to December 31.

Schedule FA was aligned to the same window deliberately so the department can reconcile your voluntary disclosure against what it receives from the US side — row by row, date by date. When you file on a calendar year, mismatches with the CRS feed are accidental. When you file on the financial year, every January-to-March transaction is structurally absent. The automated reconciliation system notices immediately.

The country code for the United States in the ITR utility is "2". Get that right too.

What "held at any point" means

You do not only report what you hold on December 31. You report every asset you held at any time between January 1, 2025 and December 31, 2025.

A stock you bought on June 15, 2025 and sold on September 1, 2025 must be in your AY 2026-27 Schedule FA. Closing value: zero. Peak value: the highest market value of that holding during its life, converted at the SBI TTBR on the date the peak occurred. Sale proceeds: disclosed in the gross proceeds column of Table A3.

This is where Tables A2 (the custodial account at your broker) and A3 (each ticker) capture two distinct values: the closing balance on December 31, and the peak balance — the high-water mark during the entire calendar year — with the date on which the peak occurred. Both are mandatory. Peak exists precisely because a closing balance alone is trivial to avoid.

RSU-specific traps

Shares vested and immediately sold (sell-to-cover). Most RSU plans sell a portion of vesting shares to cover tax withholding. Those shares exist in your brokerage account for a window of minutes or hours. They are still a peak balance. They still appear in Schedule FA — briefly at peak, zero at closing — with sale proceeds disclosed.

Shares vested in December 2025, sold in January 2026. The shares were in your account during calendar year 2025. They go into the AY 2026-27 Schedule FA with the December 31 closing value intact. The sale in January 2026 is a different calendar year. It will appear in the AY 2027-28 disclosure.

Unvested RSUs. Not reported. A grant that has not yet vested is a contingent promise, not a beneficial asset. Schedule FA has nothing to capture until the vest date, when actual shares land in your brokerage account. Confusion here typically runs in the wrong direction — filers sometimes omit vested shares thinking they are disclosing "unvested RSUs" by not filing at all. To be explicit: if shares have vested and sit in your Schwab or Shareworks account, they are in Schedule FA under Table A2 (the account) and Table A3 (the ticker).

The "sold before year-end" misconception. Selling US shares before December 31 does not remove them from the Schedule FA obligation for the year. If the shares were held for even one day between January 1 and December 31, 2025, they belong in the AY 2026-27 disclosure. Closing value is zero. That is fine. The peak balance, the date of peak, and the sale proceeds are all still required.

The exchange rate to use

Every figure in Schedule FA converts to Indian rupees using the SBI Telegraphic Transfer Buying Rate (TTBR) on the relevant date, as prescribed by Rule 115 of the Income Tax Rules. The mechanics:

• Closing balance (December 31, 2025): use SBI TTBR on December 31, 2025.
• Peak balance: use SBI TTBR on the date the peak occurred, not the year-end rate.
• Dividends: use SBI TTBR on the date the dividend was credited to your account.
• Cost of acquisition (initial value, Table A3): use SBI TTBR on the vest date. The FMV on vest date sets both your perquisite value (taxed under Schedule S) and your cost basis for capital gains — the same figure converts at the same dated rate.

The most common quiet error here: using SBI's TT Selling Rate instead of the TT Buying Rate. SBI publishes both daily. The Buying Rate is consistently lower, by a few paise per dollar. Using the Selling Rate systematically overstates your INR asset values — a small error in one year that compounds across lots and years.

If a relevant date falls on a weekend or bank holiday and SBI does not publish a rate, use the rate from the immediately preceding working day.

What the downside looks like if you get it wrong

Wrong period (financial year instead of calendar year). The ITR-2 utility accepts it. The CRS data the department has received does not match. The January-to-March 2025 holdings and transactions — RSUs that vested in February, dividends paid in March — are missing from your disclosure but present in the department's records. Outcome: scrutiny notice asking you to reconcile the discrepancy. A revised return at that point is much more expensive than a correct original filing.

Complete non-disclosure for a year you held foreign assets. Black Money Act, Section 43: ₹10 lakh flat penalty per year of non-disclosure. The Finance (No. 2) Act, 2024 introduced a ₹20 lakh aggregate threshold below which the Section 43 penalty does not apply — a genuine relief for small inadvertent cases. But the ₹20 lakh threshold is an exemption from the penalty, not from the disclosure obligation. The obligation to file Schedule FA exists regardless. And there is no statute of limitations under the Black Money Act. The Income Tax Department can reopen assessment for undisclosed foreign assets without any time bar.

Where the department treats the asset as undisclosed in assessment — not just penalised under Section 43 but treated as having been hidden — tax is levied at 30% flat on asset value, plus a further penalty of three times that tax. Total exposure: effectively 120% of the asset's value, plus the asset itself.

The CRS dimension. The Income Tax Department now receives your broker data from the US side through FATCA and CRS. It knows what you held and when. Non-disclosure in Schedule FA when CRS data shows you had assets is the scenario that produces enforcement, not inadvertence. The system was designed to catch exactly this.

The fix is simple: use the right calendar

If you're filing for...	Schedule FA covers...	NOT...
AY 2026-27 (FY 2025-26)	Jan 1, 2025 – Dec 31, 2025	Apr 1, 2025 – Mar 31, 2026
AY 2027-28 (FY 2026-27)	Jan 1, 2026 – Dec 31, 2026	Apr 1, 2026 – Mar 31, 2027

Pull January-to-December statements from your US broker. Not April-to-March. For the specific mechanics of filling in Tables A1 through A3, the country codes, the SBI rate lookups, and a worked example with NVDA and MSFT lots, see the Schedule FA for AY 2026-27 step-by-step guide. For the full statutory background — residency tests, the Black Money Act penalty regime, the CRS architecture — see the complete Schedule FA guide. The free Schedule FA generator converts broker exports to table-ready INR rows at the correct dated SBI TTBR automatically.

The calendar-year window is the one thing that trips every first-time filer. It is also the one thing that takes thirty seconds to get right once you know it. Get January 1 tattooed in your memory. The rest of Schedule FA follows from there.