RBI Introduces Standardised Reporting Forms for Guarantees under FEMA with Immediate Effect

1. Regulatory Reference:

o Based on Foreign Exchange Management Act, 1999

o Governed by FEMA 8 (R) – Guarantees Regulations, 2026

2. Who Must Report:

o Any person required to report guarantees under Regulation 7 of FEMA 8 (R)

3. New Reporting Forms Introduced:

o Form GRN Issue → For reporting issuance of guarantees

o Form GRN Modification → For changes (amount, tenure extension, pre-closure)

o Form GRN Invocation → For reporting invocation of guarantees

4. Submission Process:

o Reports to be submitted to Authorised Dealer (AD) banks

o AD banks will file returns with RBI via CIMS (Sankalan portal)

5. Reporting Timeline:

o AD banks must submit returns within 30 days from end of the respective quarter

6. Unique Transaction Number:

o Each guarantee reported via Form GRN Issue will be assigned a
Unique Guarantee Transaction Number (GTN) by AD bank

7. Late Submission Fees (LSF):

o For GRN Invocation → Amount (A) = liability created on invocation

o For GRN Issue / Modification → Amount (A) = Nil (no fund flow involved)

8. Responsibility of AD Banks:

o Ensure proper reporting to RBI

o Follow operational guidelines on CIMS portal

9. Compliance Advisory:

o Authorised Persons must inform customers/clients about these requirements

10. Legal Backing:

· Issued under Sections 10(4), 11(1), and 11(2) of FEMA

11. Effective Date:

· Effective immediately

One-Line Takeaway:

RBI has streamlined guarantee reporting under FEMA by introducing standard forms, quarterly reporting timelines, and a unique transaction tracking system.

[A.P. (DIR Series) Circular No. 01 dated April 01, 2026]

Reporting under Foreign Exchange Management Act, 1999 – Returns pertaining to Foreign Exchange Management (Guarantees) Regulations, 2026

Attention of Authorised Persons is invited to Foreign Exchange Management (Guarantees) Regulations, 2026 [FEMA 8 (R)] and Master Direction – Reporting under Foreign Exchange Management Act, 1999.

A person having the obligation to report a guarantee in terms of Regulation 7 of FEMA 8 (R), may use the following files provided on the RBI website (List of Returns Submitted to RBI) for submissions to the authorised dealer bank:

a) ‘Form GRN Issue’ – For reporting issuance of Guarantee.

b) ‘Form GRN Modification’ – For reporting any subsequent change in guarantee terms, namely - guarantee amount, extension of period or pre-closure.

c) ‘Form GRN Invocation’ – For reporting invocation of guarantee.

3. The authorised dealer bank shall thereby submit the returns to the Reserve Bank of India within thirty calendar days from the end of the respective quarter through Centralised Information Management System (CIMS) (URL: https://sankalan.rbi.org.in). Operational guidelines are being provided therein.

4. For each guarantee issuance, reported through ‘Form GRN Issue’, the authorised dealer bank shall provide a unique Guarantee Transaction Number before submission of the return to the Reserve Bank in the manner provided in the operational guidelines

5. For the purpose of computation of Late Submission Fees for delayed reporting of ‘Form GRN Invocation’, the amount involved in the delayed reporting (A) shall be the amount of liability created towards the surety on invocation. For Delayed reporting of ‘Form GRN Issue’ and ‘Form GRN Modification’, ‘A’ shall be considered to be ‘Nil’ since these returns do not capture flows.

6. Authorised Persons may bring the contents of the circular to the notice of their customers/ constituents concerned.

7. The directions contained in this circular have been issued under sections 10(4), 11(1) and 11(2) of the Foreign Exchange Management Act, 1999 (42 of 1999) and are without prejudice to permissions / approvals, if any, required under any other law.

8. These directions shall come into force with immediate effect.