FAST-DS 2026: The Foreign Asset Amnesty Returning NRIs Should Not Ignore

For nine years, Anand's UK life was tidy and entirely above board. A stocks-and-shares ISA he topped up every April. A workplace pension that quietly compounded. A small slug of ESOPs from the fintech he joined in 2018, and a Trading 212 account he barely touched. He paid every penny of UK tax due on all of it. None of it had anything to do with India — he was a non-resident, and his UK holdings were simply not India's business.

Then he moved back to Pune. And about eight months after landing, a WhatsApp forward from a cousin landed in his inbox with a headline that made his stomach drop: something about a government scheme to declare foreign assets, a deadline, and a phrase he had never had to think about before — the Black Money Act. "Anand," the cousin wrote, "did you ever tell anyone in India about your UK accounts?"

He had not. Not because he was hiding anything — he genuinely had not realised he had to. And that is the quietly dangerous gap this post is about.

This is a general explainer, not tax advice, and an unusually heavily-hedged one — because almost everything below is reported and secondary-sourced, not something we have confirmed from the statute ourselves. What we can tell you plainly is where NriDirect actually fits: we are not tax advisers, and we will not pretend to be. What we do is the unglamorous foundation underneath any Indian tax dealing — making sure your PAN status and paperwork are correct so that whatever you and your chartered accountant decide to do, the machinery underneath actually works.

What FAST-DS reportedly is#

FAST-DS — the Foreign Asset Disclosure Scheme — is reported to be a one-time voluntary disclosure, or amnesty, introduced through the Finance Bill 2026. The reporting we have seen says it was CBDT-notified around 1 February 2026, with a window of roughly six months to come forward.

The idea, as reported, is straightforward in spirit: it gives residents, NRIs and RNORs a defined window to regularise foreign assets, accounts, ESOPs and overseas income they never disclosed in India — and to do so at a materially lower cost, and with reduced prosecution risk, than if the tax department finds them first.

We want to be honest about our footing here. Every number, date and threshold in this post is drawn from secondary reporting around the Budget 2026 announcements, not from a line-by-line read of the final Act. Schemes like this routinely shift between the bill and the notification, and between the notification and the FAQs that follow. So treat all of it as orientation, and verify the specifics before you rely on a single figure.

Why this lands hardest on returning NRIs and RNORs#

If FAST-DS is aimed at anyone, it is aimed at people exactly like Anand.

While you are a non-resident, your UK ISA, your pension, your brokerage account and your ESOPs are generally not India's concern — they are UK assets, UK-taxed, and outside India's net. That is precisely why most NRIs never declare them anywhere in India. There is nothing to declare.

The problem arrives quietly with the move home. Once you tip from NRI into resident status, India's foreign-asset disclosure obligations can start to apply — the requirement, broadly, to report foreign assets and accounts in your Indian return. The transitional RNOR (Resident but Not Ordinarily Resident) window softens the income side for a couple of years, but the asset-reporting expectations are a separate question, and one that catches returnees off guard constantly. We cover the broader return mechanics in our guide to returning to India as an NRI and RNOR status, which is essential reading alongside this post.

So the classic FAST-DS candidate is someone who:

• spent years in the UK as a genuine NRI, fully UK-tax-compliant;
• holds UK ISAs, pensions, a brokerage account, perhaps some ESOPs;
• moved back to India and became resident;
• and never realised the foreign-asset reporting obligation had quietly switched on.

The cost, as reported: roughly 60 percent versus 120 percent#

Here is the number that makes people pay attention.

Under the existing Black Money (Undisclosed Foreign Income and Assets) Act, 2015, undisclosed foreign assets can attract a combined liability reported at around 120 percent — broadly tax plus a heavy penalty — together with prosecution risk. It is a deliberately punishing regime, designed to make non-disclosure frightening.

FAST-DS is reported to settle the same exposure at roughly 60 percent — described in the reporting as about 30 percent tax plus a 30 percent charge. In other words, around half the Black Money Act hit, and reportedly with the prosecution overhang lifted for those who come forward within the window.

The reported headline comparison looks like this.

We will say the obvious caveat out loud: these percentages are reported, not confirmed, and the real arithmetic on your specific assets — currency conversion, valuation dates, which year a gain sits in — is genuinely a chartered-accountant exercise. The point of the table is the shape of the trade-off, not a promise about your bill.

The small-taxpayer relief: full immunity below ₹1 crore (reported)#

There is one more reported feature that matters enormously for ordinary returnees, because most people are not sitting on vast undisclosed fortunes.

Small taxpayers — those whose undisclosed foreign assets are at or below ₹1 crore as on 31 March 2026 — are reported to receive full immunity from penalty and prosecution under the scheme. For someone whose entire "undisclosed foreign asset" is a modest ISA, a workplace pension and a few hundred shares, that is a very different proposition from the Black Money Act's worst-case spectre.

Both the ₹1 crore threshold and the 31 March 2026 valuation date are secondary-sourced, and a threshold like this is exactly the kind of detail that can move between the bill and the final Act. Confirm both before you assume you qualify — but if the reporting holds, a great many returning NRIs will fall comfortably under it.

What counts as a "foreign asset" here#

Returnees often underestimate how wide this net is, so it is worth spelling out the kinds of UK holdings that can fall within foreign-asset disclosure:

• ISAs — including stocks-and-shares ISAs. India does not recognise the ISA wrapper as tax-free; to Indian eyes it is simply a foreign investment account.
• Pensions — workplace and personal pension pots are foreign financial assets, even before you draw them.
• Brokerage and trading accounts — Trading 212, Hargreaves Lansdown, Interactive Investor and the like.
• ESOPs and RSUs — shares or options in a foreign employer, vested or unvested, are a classic blind spot.
• Foreign bank accounts — including current accounts you simply forgot to close.
• Overseas income — dividends, interest and gains arising on any of the above.

The UK-India treaty governs how some of this income is taxed once you are resident — our explainer on the India-UK double taxation treaty covers that side — but FAST-DS is about disclosure of the assets themselves, which is a distinct obligation from how the income is treated.

Why your PAN is step zero, as always#

Here is where our lane begins and ends, and where we are deliberately honest rather than salesy.

Any engagement with FAST-DS — like any Indian tax filing — runs through a valid PAN that reflects your correct residential status. The disclosure, the acknowledgement, the payment challan and every downstream record attach to your PAN. If yours is missing, dormant, or still wrongly tagged Resident from a decade ago when you first applied, that mismatch can quietly derail the process at the worst moment.

We see two PAN problems constantly with returnees:

• No PAN at all, or one buried under a long-forgotten card, that needs locating or reissuing before any filing can begin.
• A stale residential status — a PAN that says Resident when you were abroad, or has not been updated to reflect your move back — which can trigger mismatches with banks and the tax portal.

Sorting that foundation is exactly what we do. We are not the people who decide whether you should disclose, or how much you owe — that is firmly your chartered accountant's call. We are the people who make sure your PAN is correct and operative so that, when your CA is ready to act inside the reported six-month window, nothing on the identity side is blocking you.

DIY versus getting help — the honest call#

This is one of those topics where the boundary between "manageable yourself" and "absolutely get a professional" is unusually sharp.

• DIY is reasonable for: reading up so you understand what FAST-DS reportedly is, making an honest inventory of your UK assets, and — crucially — verifying the actual terms against the official notification rather than secondary reporting.
• Pay a chartered accountant for: deciding whether to disclose at all, valuing your assets correctly, computing the real liability across currency and timing, and actually making the disclosure. A one-time amnesty with Black Money Act consequences on the other side of it is not a place to improvise. This is regulated tax work and worth every rupee.
• Where we fit: the identity layer. We make sure your PAN exists, is operative and shows the right status, so the foundation under your CA's work is solid. Get that wrong and even the best adviser is blocked.

If the very idea of an undisclosed foreign asset has set off a quiet panic, take a breath. For most returning NRIs, the reported small-taxpayer immunity means this is far less frightening than the headlines — and the first practical move is rarely the scary one. It is usually just confirming your PAN reflects the right status so that whatever you decide next can actually proceed cleanly.

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Anand, for the record, did not have a problem so much as a tidy-up. His total UK holdings, once his CA converted them to rupees, sat comfortably under the reported small-taxpayer line. We had already sorted his PAN as part of his move-back housekeeping, so when he sat down with his accountant to look at FAST-DS, the identity side was already done. Whether he ultimately needed to use the scheme at all became a calm, informed decision rather than a panicked WhatsApp-driven one. The asset was never hidden. He just hadn't known the rules had changed under his feet.

If your only loose end before you talk to a CA about FAST-DS is whether your PAN is correct and operative, that is exactly the kind of thing we sort quickly and properly — so the rest of the conversation can be about the decision that matters, not the paperwork underneath it.

This guide reflects the reported features of the FAST-DS Foreign Asset Disclosure Scheme as observed and understood by NriDirect in 2026. Critically, the rate (around 60 percent), the ₹1 crore small-taxpayer threshold, the 31 March 2026 date, the roughly six-month window and the circa 1 February 2026 notification date are all drawn from secondary reporting around the Finance Bill 2026 and must be confirmed against the official CBDT notification and the Finance Act 2026 before you rely on any of them. Rules, rates, thresholds and timelines change without notice and depend entirely on your individual circumstances — verify current details with the Income Tax Department of India↗ and always consult a qualified chartered accountant before acting. NriDirect is an independent UK agent that assists only with PAN and consular paperwork; we are not a tax or financial adviser, do not provide regulated advice, and are not affiliated with the Income Tax Department or any Indian government body.