The email titled "Important Advisory: Opportunity for Voluntary Compliance regarding Foreign Assets (FAST-DS, 2026)" is an automated advisory, not a notice. The Income Tax Department sends it when data from other countries links foreign assets or income to your PAN. You need to act only if, in a year you were resident and ordinarily resident (ROR), you left a foreign asset out of Schedule FA or foreign income out of your return. The FAST-DS deadline is 31 December 2026.
Table of contents
- Is the income tax email on foreign assets a notice?
- Why did I get the email if I reported everything?
- Do NRIs and RNORs need to do anything?
- How do I check what the department holds?
- What counts as a lapse?
- Which route fits you?
- Does the ₹20 lakh limit mean I can skip FAST-DS?
- Examples: what different readers usually do
- What not to do after getting the email
Is the income tax email on foreign assets a notice?
No. The FAST-DS email is a system-generated advisory. It asks you to check the Foreign Assets Information in your Annual Information Statement (AIS) and, if anything was left out of past returns, to consider the Foreign Assets of Small Taxpayers Disclosure Scheme, 2026 (FAST-DS). The same message also went out by SMS.
FAST-DS is a one-time scheme in Chapter IV (sections 130 to 144) of the Finance Act, 2026. Declarations can be filed from 16 August 2026 to 31 December 2026, and nothing can be filed after that date.
The email does not ask for a reply and sets no date to respond to it. A formal notice is different. It is issued under a specific section of the Income-tax Act and shows up under Pending Actions on the e-filing portal.
Note: Getting the email does not mean you have to use FAST-DS. It means your PAN appears in foreign data, so the years you were ROR are worth checking.
Why did I get the email if I reported everything?
The email comes from data matching, not from a review of your returns. Under the Automatic Exchange of Information (CRS and FATCA), banks and brokers abroad report accounts held by Indian residents. CBDT started showing this data in AIS in July 2026, for calendar years 2022 to 2024, and says the view is not exhaustive. The department has also run NUDGE campaigns on Schedule FA since November 2024, so many people have had more than one message.
People who report every year still get the email for a few common reasons:
- An earlier year is missing. Reporting correctly for the last two years does not fix the years before you started.
- The account was left out. The shares were in Schedule FA, but the brokerage account holding them (Table A2, foreign custodial accounts) was not.
- The income was left out. Dividends, interest or sale gains on the asset never reached the income schedules or Schedule FSI.
- The wrong form was used. ITR-1 has no Schedule FA, so a year filed in ITR-1 while holding foreign assets is a year with no disclosure.
- The residential status was wrong. A past return or the portal profile shows you as resident for a year you were abroad.
If none of these apply and every year you were ROR is complete, there is nothing to fix. Keep your statements and returns together in case a notice ever follows.
Do NRIs and RNORs need to do anything?
Usually not, for the years they were NRI or RNOR. Schedule FA is for residents who are ordinarily resident, and the Black Money Act's prosecution provision for Schedule FA covers a "resident other than not ordinarily resident".
NRIs still received the email, often because an account abroad is linked to their Indian PAN or because a past return was filed with resident status. If you are an NRI, check three things:
- Residential status in each past return. If any return was filed as resident for a year you lived abroad, that is the issue to correct, not FAST-DS.
- Years you were ROR. Years before you moved abroad, or after you came back, can still be lapse years.
- Whether FAST-DS applies to you at all. People who are NRIs today can use FAST-DS for income or assets from a year they were resident (CBDT FAQ Q6 and Q7). If you were NRI or RNOR in every year you held the asset, the scheme is not for you.
For a returning NRI, the lapse usually starts in the first ROR year, not during RNOR. To work out which years were which, see Resident vs RNOR vs non-resident and foreign asset disclosure for RNORs.
How do I check what the department holds?
Start with the AIS report, then go further back with your own records, because the AIS view is incomplete.
- Log in to the e-filing portal and open AIS.
- Go to Compliance Portal, then Reports, then Foreign Assets Information. It shows CRS and FATCA data for calendar years 2022 to 2024, with calendar year 2025 data due later in 2026 (CBDT note).
- Compare each entry with Schedule FA and the income schedules in your return for the same year.
- List every foreign asset you held while ROR, including any that never appear in AIS. CBDT says all foreign assets must be reported whether or not they show up there.
A blank Foreign Assets Information report does not mean you are clear.
When you list your holdings, include the ones people forget most often:
- Foreign bank accounts, including dormant student or salary accounts
- Brokerage accounts, including US stock apps and plan administrators that hold employer shares
- RSU, ESPP or ESOP shares from a foreign employer
- Foreign insurance policies and retirement accounts such as a 401(k)
- Property abroad
- Dividends, interest and sale gains from any of the above
For how each of these goes into the return, see the Schedule FA guide.
What counts as a lapse?
There are two kinds of gap, and they cost different amounts: an asset left out of Schedule FA, and foreign income that was never taxed in India.
| Gap | Example | What it can cost under the Black Money Act |
|---|---|---|
| Asset left out of Schedule FA, bought with taxed money or while you were NRI | RSU shares taxed through payroll but missing from Schedule FA | ₹10 lakh penalty for each year it was left out, except foreign assets other than property worth up to ₹20 lakh in total |
| Foreign income never offered to tax in India | US dividends, foreign bank interest, gains on selling foreign shares | 30% tax plus a penalty of three times that tax, so 120% of the amount |
| Asset with no explained source | An account funded with money that was never taxed | 30% tax plus three times the tax, so 120% of the asset's value |
These figures come from the Black Money Act, 2015 and the ₹20 lakh relief added later (see the ₹20 lakh section below). Prosecution is also possible for wilful non-disclosure.
Most people who got the email fall in the first row. Many also have a small amount in the second, such as a few years of dividends that never reached the return.
Which route fits you?
There are five ways to fix a gap. Which one fits depends on the year, the kind of gap and the amount.
| Route | Fits when | Cost | Deadline | Black Money Act immunity |
|---|---|---|---|---|
| Report correctly from now | Past gaps are only assets covered by the ₹20 lakh relief, with no missed income | Nil | Your next return | Not needed if the relief applies |
| Revised return for FY 2025-26 | The latest return (AY 2026-27) left something out | Tax and interest on anything missed | 31 March 2027 | No |
| Updated return (ITR-U) | Foreign income was left out of a recent year | Tax and interest, plus additional tax of 25% to 70% of that amount | 48 months from the end of the assessment year | No |
| FAST-DS, Row 1 | Foreign income never taxed, or assets with no explained source, up to ₹1 crore in total | 60% of the value (30% tax plus an equal amount) | Form 1 by 31 December 2026 | Yes |
| FAST-DS, Row 2 | Assets bought with taxed money, or while NRI, left out of Schedule FA, up to ₹5 crore in total | Flat ₹1 lakh | Form 1 by 31 December 2026 | Yes |
The FAST-DS rows, limits and amounts are set out in section 133 of the Finance Act, 2026. A valid declaration gives immunity from further tax, penalty and prosecution under the Black Money Act for what was declared, for every year up to FY 2025-26 (section 139). It does not cover anything left out of Form 1, and it does not cover other laws.
Note: Above ₹1 crore (Row 1) or ₹5 crore (Row 2), FAST-DS cannot be used at all. There is no partial declaration (CBDT FAQ).
If you use ITR-U, the extra tax depends on the year
The Finance Act, 2025 extended the updated return window to 48 months from the end of the assessment year and added higher additional tax for later years (Budget 2025 memorandum). For an updated return filed before 31 March 2027:
| Income earned in | Assessment year | Open until | Additional tax if filed before 31 March 2027 |
|---|---|---|---|
| FY 2021-22 | AY 2022-23 | 31 March 2027 | 70% |
| FY 2022-23 | AY 2023-24 | 31 March 2028 | 60% |
| FY 2023-24 | AY 2024-25 | 31 March 2029 | 50% |
| FY 2024-25 | AY 2025-26 | 31 March 2030 | 25% |
| FY 2025-26 | AY 2026-27 | Use a revised return until 31 March 2027 | None |
The additional tax is a percentage of the tax and interest on the extra income, not of the income itself. FY 2020-21 and earlier can no longer be fixed through ITR-U, so for those years FAST-DS is the only voluntary route.
ITR-U has limits that matter here:
- It cannot be filed if it is a return of loss, lowers your tax or raises your refund. It is built to report extra income.
- If your only gap is a missing Schedule FA entry with no extra income, an updated return may not be possible for that year.
- It settles the Income-tax Act side. Unlike FAST-DS, it carries no express immunity under the Black Money Act.
Does the ₹20 lakh limit mean I can skip FAST-DS?
Possibly. If your only gap is foreign assets other than property, worth ₹20 lakh or less in total, and you have no unreported foreign income, the Black Money Act's penalty and prosecution for that gap no longer apply.
The relief came in two steps:
- Penalty, from 1 October 2024. The Finance (No. 2) Act, 2024 changed sections 42 and 43 so the ₹10 lakh penalty does not apply to foreign assets other than immovable property worth up to ₹20 lakh in aggregate. The limit used to be ₹5 lakh and covered only bank accounts (Budget 2026 memorandum).
- Prosecution, also from 1 October 2024. The Finance Act, 2026 added matching relief to sections 49 and 50, with effect from the same date (Finance Act, 2026).
What the ₹20 lakh relief does not do:
- It does not cover income. Dividends, interest or gains that were never taxed are still taxable. The relief only removes the penalty and prosecution for not reporting the asset.
- It does not cover property. Immovable property abroad gets no ₹20 lakh relief, so FAST-DS Row 2 matters most for foreign flats and land.
- It does not remove the duty to report. The asset still has to go into Schedule FA from your next return.
Two points have no official answer yet:
- Older years. The relief runs from 1 October 2024. CBDT has not said how it applies to returns filed before that date that left an asset out.
- What counts toward ₹20 lakh. CBDT has not issued a circular on whether only the undisclosed assets are added up, or all foreign assets.
Note: If your holdings are close to ₹20 lakh, the gap goes back before October 2024 or you also have missed income, the ₹1 lakh Row 2 fee buys certainty that the ₹20 lakh relief alone may not.
Examples: what different readers usually do
1. RSU holder with a few missed years
Example. Suppose you work in India for a US-listed company and your RSUs have vested every year since 2021, taxed as salary through payroll. You left the shares out of Schedule FA for AY 2022-23 to AY 2024-25 and started reporting them in AY 2025-26. The shares are worth ₹45 lakh on 31 March 2026, and ₹60,000 of dividends from those years never reached your return.
The shares were bought with taxed salary, so they fall in Row 2. The dividends are foreign income that was never taxed, so they fall in Row 1. Because the shares are above ₹20 lakh, the ₹20 lakh relief does not help.
| Item | FAST-DS row | Amount payable |
|---|---|---|
| RSU shares worth ₹45 lakh, from taxed salary | Row 2 (flat fee) | ₹1,00,000 |
| Unreported dividends of ₹60,000 | Row 1 (60%) | ₹36,000 |
| Total | ₹1,36,000 |
The result: ₹1,36,000 settles the past years with Black Money Act immunity
The dividends alone could also go through ITR-U for the years still open, but that would leave the Schedule FA gap on shares above ₹20 lakh without immunity. Shares are valued at the higher of cost and the average of the day's high and low price on 31 March 2026 (FAST-DS Rules, rule 3). For more on RSUs in Schedule FA, see Schedule FA for RSU holders.
2. Investor who used a US stock app
Example. Suppose you bought and sold US shares through an app from FY 2021-22 to FY 2023-24, with the account never above ₹3 lakh. You made ₹1.36 lakh in gains and dividends and reported none of it, and the account was never in Schedule FA.
The account is well under ₹20 lakh, so the asset side is covered by the relief from October 2024 (subject to the open point on older years). The ₹1.36 lakh is untaxed foreign income, and that is what needs fixing. You have two choices:
- ITR-U for each year. All three years are still open (see the ITR-U table above). You pay tax at your slab rate, interest, and additional tax of 50% to 70%.
- FAST-DS Row 1. You pay 60% of ₹1.36 lakh, which is ₹81,600, with Black Money Act immunity.
At lower slab rates ITR-U usually costs less. At the 30% slab, once interest and 60% to 70% additional tax are added, the two come close, and FAST-DS adds immunity.
3. Returning NRI with accounts abroad
Example. Suppose you moved back from the UK, became ROR in FY 2023-24, and kept your UK salary account and a brokerage account, both funded while you were NRI. Neither was in Schedule FA for AY 2024-25 or AY 2025-26.
Assets bought with income earned while non-resident fall in Row 2, so the fee is ₹1 lakh if the total is ₹5 crore or less. Watch the bank account value: FAST-DS values a foreign bank account at the sum of all deposits since it was opened, not its balance (rule 3(1)(e)). Ten years of salary credits can add up to far more than the current balance. Any interest or dividends earned after you became ROR and never reported fall in Row 1.
4. NRI who has lived abroad throughout
Example. Suppose you have lived in Dubai since 2019 and filed Indian returns as a non-resident, with only NRO interest in India. You still got the email.
For the years you were non-resident, there is no Schedule FA lapse and FAST-DS does not apply. Check two things: that every return since 2019 shows non-resident status, and whether you held foreign assets in any year before you left while you were ROR. If both are fine, nothing needs to be done.
What not to do after getting the email
- Don't reply with account details. The email asks for no reply. Corrections go through a return or FAST-DS Form 1 on the e-filing portal.
- Don't pay before you get Form 2. FAST-DS is paid by challan ITNS 289 after the department issues the Form 2 order, and the portal warns that these payments cannot be corrected or refunded.
- Don't treat a blank AIS report as a clean chit. CBDT says the AIS view is not exhaustive.
- Don't wait until the last week. Form 1 cannot be filed after 31 December 2026. Payment is due within two months from the end of the month you receive Form 2, with two more months allowed at 1% interest a month (CBDT FAQ Q41 to Q44).
- Don't skip the next return. FAST-DS immunity stops at FY 2025-26. The same assets must appear in Schedule FA, and their income must be taxed, from the next return onward. For what changes under the new law from Tax Year 2026-27, see Income-tax Act 2025 changes for foreign asset holders.
About Paasa
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- Records in one place: holdings, dividends and trades across every market sit in one account, so the figures for Schedule FA and Schedule FSI come from one statement rather than several apps.
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