RBI Expands Reporting Requirements for INR Derivative Transactions by AD Cat-I Banks

1. Reserve Bank of India issued Circular No. 08 dated April 27, 2026 for enhanced reporting by AD Category-I Banks.

2. AD Cat-I banks must now report all OTC foreign exchange derivative contracts involving INR undertaken globally by their related parties to the Trade Repository of Clearing Corporation of India Ltd.

3. Reporting covers both deliverable and non-deliverable derivatives, including offshore transactions.

4. Exemptions from reporting:

o Back-to-back transactions

o Transactions with other AD Cat-I banks in India

o Contracts with notional value up to USD 1 million (optional)

5. Phased compliance timeline:

o From July 1, 2027: Reporting of parent entity transactions begins

o 70% coverage of related-party transactions by July 2027

o 80% coverage by January 2028

o 100% reporting by July 1, 2028

6. Banks must report detailed transaction data such as notional value, counterparty, maturity, and currency.

7. Reporting should be done on the transaction date or within two working days.

8. “Related party” definition follows Ind AS 24 / IAS 24 standards, excluding associates.

9. The directions are issued under powers of the RBI Act, 1934 and FEMA, 1999.

Overall Insight:
The circular significantly broadens transparency in INR-linked global derivative markets, aiming to strengthen regulatory oversight and risk monitoring.

[A.P. (DIR Series) Circular No. 08 dated April 27, 2026]

Reporting instructions for Authorised Dealer Category-I Banks

Please refer to the Master Direction - Risk Management and Inter-Bank Dealings dated July 5, 2016, as amended from time to time, in terms of which Authorised Dealer Category-I (AD Cat-I) banks are required to report all over-the-counter (OTC) foreign exchange derivative contracts and foreign currency interest rate derivative contracts, undertaken by them directly or through their overseas entities to the Trade Repository (TR) of Clearing Corporation of India Ltd. (CCIL). A reference is also invited to the Master Direction – Reserve Bank of India (Rupee Interest Rate Derivatives) Directions, 2025, as amended from time to time, in terms of which market-makers in the Rupee Interest Rate Derivative (IRD) market are required to report all OTC IRD transactions undertaken by them directly or through their overseas entities as well as all Rupee IRD transactions undertaken globally by their related parties to the TR of CCIL.

2. On a review, it has been decided that an AD Cat-I bank shall report all OTC foreign exchange derivative contracts involving the Indian Rupee (INR) undertaken globally by its related parties to the TR of CCIL. Such reporting shall be in terms of the following:

(i) An AD Cat-I bank shall report the necessary details of the OTC foreign exchange derivative contracts involving INR undertaken by its offshore related parties to the TR of CCIL. The related party of the AD Cat-I bank may also report the details of such derivatives undertaken by it independently to the TR of CCIL.

(ii) All OTC deliverable and non-deliverable foreign exchange derivative contracts involving INR, undertaken globally by the related parties of the AD Cat-I bank in India shall be reported.

(iii) With a view to providing operational flexibility, such reporting shall be subject to the following requirements:

(a) An AD Cat-I bank is not required to report transactions undertaken in terms of the back-to-back arrangement, as defined in the Master Direction - Risk Management and Inter-Bank Dealings dated July 5, 2016, as amended from time to time, and transactions undertaken by the related parties with other AD Cat-I banks in India, as these transactions are being reported to the TR of CCIL under extant instructions;

(b) An AD Cat-I bank shall have the option of not reporting transactions where the notional of the contract does not exceed USD 1 million or equivalent;

(1) with effect from July 1, 2027, all foreign exchange derivative contracts involving INR undertaken by its parent, including the branches of the parent, are reported by it;

(2) with effect from July 1, 2027, transactions reported by it constitute at least 70 per cent of the notional value of all foreign exchange derivative contracts involving INR undertaken by its related parties other than the parent;

(3) with effect from January 1, 2028, transactions reported by it constitute at least 80 per cent of the notional value of all foreign exchange derivative contracts involving INR undertaken by its related parties other than the parent; and

(4) with effect from July 1, 2028, all foreign exchange derivative contracts involving INR undertaken by its related parties other than the parent are reported by it; and

(d) For the purpose of computation, to ensure compliance with (c) (2) - (c) (4) above, transactions indicated at (a), (b) and (c) (1) above may be excluded.

(iv) An AD Cat-I bank shall report all elements of the transactions which are relevant to provide meaningful information about the transaction. This will include, but not be limited to, the notional value, name of the counterparty, maturity date, currency, specifications etc., as applicable to the transaction. The central counterparty may be reported as the counterparty only in cases where the covered transaction is undertaken on an anonymous trading platform and is cleared by the central counterparty. The reporting formats shall be as indicated by CCIL with the prior approval of the Reserve Bank.

(v) Transaction shall be reported preferably on the date of transaction, but in any case, within two working days from the date of transaction.

3. For the purpose of these directions,

(i) the term "related party" shall have the same meaning as assigned to it under the Indian Accounting Standard (Ind AS) 24 - Related Party Disclosures or International Accounting Standard (IAS) 24 - Related Party Disclosures or any other equivalent accounting standard, provided that the term 'related party' shall exclude associates, as specified in the Ind AS 24 or IAS 24 or any other equivalent accounting standard; and

(ii) OTC derivatives shall mean derivatives other than those which are traded on stock exchanges and shall include those traded on electronic trading platforms.

4. These directions are issued under the powers vested in the Reserve Bank of India under Section 45W of the Reserve Bank of India Act, 1934, and 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.