What is the FAST-DS 2026 amnesty scheme?

FAST-DS (Facilitation for Assessment of Specified Tax-payers — Disclosure Scheme) is a one-time amnesty window announced by India's CBDT allowing resident and non-resident Indians to voluntarily disclose previously unreported foreign assets and income. It covers foreign bank accounts, ESOPs, mutual funds, and other overseas financial interests, offering reduced penalties and immunity from prosecution under the Black Money Act.

Do I need to disclose my German salary account under FAST-DS?

If you are an NRI for Indian tax purposes, you are generally not required to report foreign assets in your Indian return. However, if your residential status was 'Resident' or 'Resident but Not Ordinarily Resident' (RNOR) for any year where you held undisclosed German accounts, you may need to file under FAST-DS. Consult a qualified tax professional to determine your exact obligation.

What are the penalties under the Black Money Act for not disclosing German accounts?

The Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015, imposes a penalty of ₹10 lakh per assessment year for failure to disclose foreign assets in Schedule FA of your Indian income tax return. Additionally, undisclosed foreign income is taxed at a flat 30% plus a 90% penalty — effectively a 78% total tax rate — with potential prosecution carrying up to 10 years of imprisonment.

Are ESOPs from a German employer covered under FAST-DS?

Yes. If you held vested ESOPs or RSUs from a German employer during a year when you were an Indian tax resident (or RNOR) and did not report them in Schedule FA of your Indian return, they count as undisclosed foreign assets. The FAST-DS amnesty allows you to disclose these and pay a reduced tax and penalty instead of facing the full Black Money Act consequences.

India's FAST-DS 2026 Amnesty: Disclose Your German Bank Accounts & ESOPs to Avoid ₹10 Lakh/Year Black Money Act Penalties

Why Every Indian in Germany Needs to Know About FAST-DS

If you are an Indian living in Germany — whether you are a Blue Card IT professional, a PhD researcher, or a working student — there is a good chance you have a German bank account, a Depot (brokerage account), or ESOPs/RSUs from your employer. These are completely normal financial assets for someone living in Germany.

But here is the part most people miss: India's Black Money Act can impose a ₹10 lakh penalty per year for every year you failed to disclose these foreign assets in your Indian income tax return — even if you owed zero tax on them.

India's new FAST-DS 2026 (Facilitation for Assessment of Specified Tax-payers — Disclosure Scheme) offers a one-time amnesty window to come clean. If you have ever been confused about your Indian tax residency status, skipped filing an Indian return, or simply did not know about Schedule FA, this article is for you.

Disclaimer: This article is for educational purposes. FAST-DS rules are complex and evolving. Always consult a qualified Steuerberater or Indian CA for your specific situation.

Who Is Actually Affected? The Residency Trap

The key question is not where you live — it is what your Indian tax residency status was for each financial year.

Indian Tax Residency — Quick Recap

Under India's Income Tax Act (and the new 2025 Act continuing these rules), you are a Resident if you spent:

182 days or more in India during the financial year, OR
60 days or more in India during the FY AND 365 days or more in India in the preceding 4 years

The 60-day rule has a crucial exception: if you are an Indian citizen who left India for employment, the threshold is 182 days (not 60). But the new 120-day rule (introduced from FY 2020-21) added a twist — Indian citizens earning over ₹15 lakh from Indian sources who spend 120–181 days in India become RNOR (Resident but Not Ordinarily Resident).

⚠️The Year You Moved to Germany Matters Most

If you moved to Germany in, say, September 2023, you likely spent April–August 2023 in India — roughly 150 days. Depending on your prior 4-year history, you may have been an Indian Resident or RNOR for FY 2023-24. In that year, you were required to disclose your German bank account (even if opened in October 2023) in Schedule FA of your Indian return. Most people did not.

The Bottom Line

| Status | Must report foreign assets in Schedule FA? | |---|---| | Resident (ROR) | ✅ Yes — all global assets | | Resident but Not Ordinarily Resident (RNOR) | ✅ Yes — foreign assets must be disclosed (income taxable only if derived from India) | | Non-Resident (NRI) | ❌ No — Schedule FA not applicable |

If you were Resident or RNOR for even one year while holding a German bank account, Depot, or ESOPs — and you did not file Schedule FA — the Black Money Act technically applies to you.

What Exactly Must Be Disclosed?

Under Schedule FA (Foreign Assets) of the Indian income tax return, the following German-held assets require disclosure:

Bank accounts — your Girokonto (current account) at Commerzbank, N26, DKB, etc.
Depots / brokerage accounts — Trade Republic, Scalable Capital, ING Depot
ESOPs, RSUs, and stock options from your German (or global) employer
Immovable property — if you bought a flat in Germany
Any other foreign asset exceeding specified thresholds

📘Ankit's Situation — A Typical Blue Card IT Professional

Ankit moved to Munich in August 2022 on a Blue Card. He opened a Deutsche Bank account in September 2022. His employer, a DAX-listed company, granted him 200 RSUs vesting over 4 years.

For FY 2022-23 (April 2022 – March 2023), Ankit spent April–July in India (≈120 days). With his prior India residence history, he was classified as RNOR for that year. He filed his Indian return showing only his Indian salary income — but never filled in Schedule FA.

He has been NRI for FY 2023-24 onwards. But for that one RNOR year, his German bank account and vesting RSUs were unreported foreign assets.

Under the Black Money Act: ₹10 lakh penalty for FY 2022-23 alone.

The Penalties You Are Facing Without FAST-DS

Let us be very clear about what India's Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 says:

Even if you had zero taxable income from the German account (e.g., your Girokonto earning €0.00 interest), the ₹10 lakh penalty for non-disclosure still applies. The penalty is for not reporting the asset, not for hiding income.

What FAST-DS 2026 Offers

The FAST-DS amnesty scheme provides a significantly reduced penalty structure for voluntary disclosure:

The biggest relief is the waiver of the ₹10 lakh per-year penalty for Schedule FA non-disclosure. For someone like Ankit with one problematic year, that alone saves ₹10 lakh. For someone who has been RNOR/Resident for multiple years, the savings multiply.

A Worked Example: How Much Could You Save?

Let us walk through a realistic scenario.

📘Meera — PhD Student Turned Postdoc

Meera came to Germany in October 2021 for her PhD. She was RNOR for FY 2021-22 and FY 2022-23 (she visited India for extended periods). She opened a DKB account in November 2021 and received a small stipend. She also had a Trade Republic Depot where she invested €5,000.

She never filed Schedule FA for those two years. Her German account earned about €45 in interest across both years.

Meera saves over ₹20 lakh by using the FAST-DS window — for €45 worth of interest income. The absurdity of the Black Money Act's ₹10 lakh fixed penalty is exactly why this amnesty exists.

ESOPs and RSUs — The Hidden Trap for IT Professionals

If you work at SAP, Siemens, Infosys (German branch), or any company granting equity, pay close attention.

Vested but unexercised stock options and RSUs sitting in a foreign Depot are foreign assets under Schedule FA — even if you have not sold them yet.

⚠️When ESOPs Become a Problem

Your company grants you 500 RSUs through a US-based brokerage like E*Trade, Fidelity, or Charles Schwab. Even though you live in Germany, the account is "foreign" from India's perspective. If you were Resident/RNOR for any year while these RSUs were vesting, you had to report them. The peak value during the year matters, not just the vesting date.

What to Report for ESOPs Under FAST-DS

Account details of the foreign brokerage (E*Trade, Schwab, etc.)
Peak value of holdings during the relevant financial year
Income from sale, if any, during that year
Cost basis — your employer's documentation of the FMV at vesting

The German Side — Your 2025 Steuererklärung

While you sort out the Indian side, do not forget your German obligations. Your 2025 tax return is due by 31 July 2026 (self-filing or via platforms like TaxDost). If a licensed Steuerberater files for you, the deadline extends to 28 February 2027.

On the German side, all income from Indian FDs, NRO interest, and capital gains must be declared. The DTAA between India and Germany ensures you are not double-taxed, but you must claim the credit actively.

💡Coordinate Both Filings

If you are disclosing German accounts under FAST-DS in India, make sure the numbers are consistent with what you report in your German Steuererklärung. The Finanzamt and Indian IT department increasingly exchange data under the Common Reporting Standard (CRS). Discrepancies can trigger inquiries on both sides. TaxDost can help you ensure your German filing is accurate and consistent.

Step-by-Step: What to Do Right Now

Determine your Indian tax residency status for every financial year since you arrived in Germany. Count your days in India carefully — use passport stamps and travel records.
List all foreign assets you held during any year you were Resident or RNOR — German bank accounts, Depots, ESOPs/RSUs, insurance policies, property.
Consult a qualified Indian CA familiar with the Black Money Act and FAST-DS. This is not a DIY exercise.
File your FAST-DS disclosure before the amnesty window closes. The exact deadline is set by CBDT — monitor official notifications.
File your 2025 German Steuererklärung by 31 July 2026 to stay compliant on the German side.

Common Mistakes to Avoid

"I'm NRI, so I'm safe" — You may be NRI now, but were you NRI in your transition year? Check every year independently.
"My German account has no interest" — The penalty is for non-disclosure of the asset, not the income. Even a zero-interest Girokonto must be reported if you were Resident/RNOR.
"My ESOPs haven't vested yet" — Partially vested RSUs and even unvested options with exercise rights may still need to be reported.
"India won't find out" — Germany and India exchange financial account information under CRS/AEOI. Your Commerzbank data is already being shared.

Get Your German Tax Filing Right — Start With TaxDost

While FAST-DS handles your Indian disclosure, your 2025 German Steuererklärung needs to be filed accurately by 31 July 2026. Whether you have ESOPs, Indian FD interest, or NRO account income, TaxDost is built specifically for Indians in Germany and walks you through every relevant form — including Anlage AUS for DTAA credits and Anlage KAP for foreign capital income.

Use the TaxDost calculator at taxdost.de to estimate your 2025 German tax refund →

Get started in minutes, file in English, and make sure both your German and Indian tax records tell the same, accurate story. Your future self — and your wallet — will thank you.