The International Financial Services Centres Authority (IFSCA) has prescribed a fixed format for the quarterly reporting of non-compliance by the Bullion Exchange and the Bullion Clearing Corporation in the IFSC. The circular, titled "Format for reporting of non-compliance(s) under the IFSCA (Bullion Market) Regulations, 2025", was issued on 12 November 2026 and is in force with immediate effect. From now on, the Compliance Officer of each institution must report every instance of non-compliance in the nine-column format set out in the Annexure to the circular, and must file that report with IFSCA within 45 calendar days from the end of each quarter — including a Nil Report when there has been no non-compliance at all.
In plain terms, this circular does not create a new duty to report. It gives the existing duty a fixed shape, a fixed clock and a fixed answer for a clean quarter: one prescribed table, 45 calendar days after quarter-end, and a Nil Report even when nothing went wrong.
Quick Answer
IFSCA Circular IFSCA-PMTS/10/2023-Precious Metals/2026/8, dated 12 November 2026, prescribes a nine-column format for the quarterly non-compliance report that the Compliance Officer of the Bullion Exchange and the Bullion Clearing Corporation in the IFSC must file within 45 calendar days of each quarter-end, with a Nil Report mandatory when there is no non-compliance.
What changed on 12 November 2026
The change is narrow and entirely about form. The duty to report non-compliance is not new. What is new is that IFSCA has now specified the manner of the quarterly report, as Regulation 31 of the IFSCA (Bullion Market) Regulations, 2025 required it to do. Until this circular, the quarterly report had to be submitted "in a manner specified by the Authority" — but no manner had been specified. The circular of 12 November 2026 supplies that missing piece: a single Annexure format that both institutions must now use.
The circular's operative part can be stated in three points:
- A prescribed format now exists. The Annexure sets out a nine-column table. Every instance of non-compliance must be reported against those nine columns.
- The deadline is 45 calendar days from the end of each quarter. The report in the specified format must reach IFSCA within that period. The circular says "45 calendar days", so the count runs in calendar days, not working days.
- A Nil Report is mandatory. If there is no instance of non-compliance during the relevant reporting period, a Nil Report must still be submitted within the prescribed timeline. A clean quarter is not a reason to file nothing; it is a reason to file a Nil Report.
The circular was issued under sections 12 and 13 of the International Financial Services Centres Authority Act, 2019, read with regulation 78 of the IFSCA (Bullion Market) Regulations, 2025. It is signed by Ramaneesh Goyal, General Manager, Market Regulation Division, Department of Metals and Commodities. It is addressed to the Bullion Exchange in the IFSC and the Bullion Clearing Corporation in the IFSC.
The rule behind the circular: Regulation 31
Regulation 31 of the IFSCA (Bullion Market) Regulations, 2025 provides for a Compliance Officer in these terms:
(a) A bullion exchange or bullion clearing corporation shall appoint a Compliance Officer responsible for monitoring compliance with the Act or relevant rules, regulations and circulars, guidelines or directions issued thereunder by the Authority or any other regulatory Authority, and also for the redressal of customers' grievances.
(b) The Compliance Officer shall immediately and independently report to the Authority any non-compliance observed by her, and shall also submit a report thereon to the Authority on a quarterly basis within 45 days from the end of the quarter, in a manner specified by the Authority.
Two duties sit inside that one regulation, and the circular touches only the second. The first duty — immediate and independent reporting of any non-compliance observed — is unchanged. The second duty — the quarterly report — is the one that now has a prescribed manner. The circular does not alter the immediate-reporting duty, does not change who must report, and does not change the 45-day period that Regulation 31 already stated. It specifies the format in which the quarterly report must be made.
The scope of the Compliance Officer's monitoring role also defines what counts as non-compliance for this report. Under Regulation 31(a), the Compliance Officer monitors compliance with the IFSCA Act, the relevant rules, regulations and circulars, guidelines or directions issued under the Act by IFSCA or by any other regulatory authority — and is also responsible for the redressal of customers' grievances. The quarterly report therefore covers non-compliance with that full body of requirements, not only with the Bullion Market Regulations themselves.
The background: this duty goes back to 2020
The circular itself sets out the history. Since the notification of the IFSCA (Bullion Exchange) Regulations, 2020, the Compliance Officer has had primary responsibility to monitor compliance, to maintain a database of instance(s) of any non-compliance(s), and to immediately and independently report such non-compliance(s) to IFSCA. That responsibility was set out in sub-regulation (2) of regulation 24 of the 2020 Regulations.
The IFSCA (Bullion Market) Regulations, 2025 then carried the framework forward and added the quarterly reporting requirement. Regulation 31 kept the immediate and independent reporting duty and added the obligation to submit a report on a quarterly basis within 45 days from the end of the quarter, in a manner specified by the Authority. The 12 November 2026 circular is the step that specifies that manner. Read together, the sequence is: 2020 — monitoring, a database of instances, and immediate independent reporting; 2025 — the same duties restated, plus a quarterly report in a manner to be specified; 2026 — the manner is now specified, as a nine-column format, with 45 calendar days and a mandatory Nil Report.
Old position vs new position
This is a format-and-process circular, not a change to the substantive compliance standards. Its practical effect is nevertheless real: a prescribed format removes ambiguity about what IFSCA expects to see each quarter, and a Nil Report requirement removes ambiguity about what happens in a clean quarter. Silence is no longer an option in either case.
The Annexure: the nine-column reporting format
The heart of the circular is its Annexure. For each instance of non-compliance, the quarterly report must capture nine pieces of information, in the order IFSCA prescribes them:
Columns 1 to 4 identify and explain the breach. Columns 5 and 6 put it in context — a first instance or a repeat, and how long it has been running. Column 7 records what has already been done, including any action by any regulatory authority. Columns 8 and 9 state the present position — whether it still continues, and if so, by when and how it will be fixed. That is why the database duty from the 2020 Regulations matters: a Compliance Officer who has maintained a database of instances of non-compliance will be able to answer columns 5 and 6 from the record, rather than reconstructing the history each quarter.
Who is affected
The Bullion Exchange in the IFSC and the Bullion Clearing Corporation in the IFSC. Each institution's Compliance Officer must now file the quarterly report in the prescribed format. Each institution reports on its own non-compliance; the circular does not provide for a combined report. The format does not change what either institution must comply with; it changes how its non-compliance, if any, is presented to IFSCA each quarter.
The Compliance Officers. The circular adds a concrete, recurring deliverable to the role defined by Regulation 31 — a quarterly report in a fixed format, on a fixed 45-calendar-day clock, with a Nil Report when there is nothing to report. The quarterly report is part of the same independent reporting line to the Authority as the immediate-reporting duty.
Market participants. Bullion trading members and clearing members are not themselves required to file this report — the circular imposes no filing duty on them. But the report concerns the institutions they rely on, and a standardised quarterly report gives IFSCA a consistent view of how those institutions are performing. This is a process circular: it does not change trading, clearing, settlement or membership requirements.
What the Compliance Officer must do next
The circular is in force with immediate effect, so the Compliance Officer should treat the prescribed format as the format for the next quarterly report onwards. The steps below follow directly from the circular and Regulation 31.
- Adopt the Annexure format now. Use the nine-column table as the template. Each instance of non-compliance gets one row, with all nine columns completed.
- Reconcile the report with the non-compliance database. Check the database maintained under the 2020 Regulations against the nine columns, and fill any gap — instrument and provision, details and reasons, first instance and period of continuance, corrective measures and any regulatory action — before the report is due.
- Keep the immediate-reporting duty separate. If a non-compliance is observed, report it to IFSCA immediately and independently, as Regulation 31(b) requires. The quarterly report then records it again, in the prescribed format, with its corrective measures and its status on the date of reporting.
- Work to the 45-calendar-day clock. Submit the report within 45 calendar days from the end of each quarter, treating the 45th calendar day as the last day. Allow time inside that window for review and any internal sign-off the institution requires; the circular does not state an internal approval process.
- File a Nil Report for a clean quarter. If there is no instance of non-compliance in the period, submit a Nil Report within the prescribed timeline. Do not file nothing — the Nil Report is the record that the quarter was reviewed and found clean.
- Close each continuing item with a timeline and a plan. For any non-compliance that continues on the date of reporting, state the expected timeline for rectification and the corrective measures envisaged, and keep the evidence behind each statement in the report.
What this circular does not do
It does not impose a new filing duty on bullion trading members or clearing members, change the substantive compliance obligations of the Bullion Exchange or the Bullion Clearing Corporation, or state a penalty for late filing or a fee for filing the report. None of those points appears in the circular, and none should be read into it.
Frequently asked questions
What is the IFSCA circular on bullion market non-compliance reporting dated 12 November 2026?
It is IFSCA Circular IFSCA-PMTS/10/2023-Precious Metals/2026/8, dated 12 November 2026, titled "Format for reporting of non-compliance(s) under the IFSCA (Bullion Market) Regulations, 2025". It prescribes the nine-column Annexure format for the quarterly non-compliance report of the Bullion Exchange and the Bullion Clearing Corporation in the IFSC.
Who must file the quarterly non-compliance report?
The Compliance Officer of the Bullion Exchange in the IFSC and the Compliance Officer of the Bullion Clearing Corporation in the IFSC. Regulation 31 requires the report quarterly, within 45 days from the end of the quarter, in a manner specified by the Authority — and this circular now specifies that manner.
What is the deadline for the quarterly report?
Within 45 calendar days from the end of each quarter, in the specified format. The deadline applies to every quarter, including a quarter with no non-compliance.
Is a Nil Report required if there is no non-compliance in the quarter?
Yes. If there is no instance of non-compliance during the relevant reporting period, a Nil Report shall be submitted within the prescribed timeline. A clean quarter still requires a filing.
What are the nine columns in the reporting format?
(1) The Act, rules, regulations, circulars or subsidiary instructions breached; (2) the specific provision — section, regulation or clause number; (3) details of the non-compliance; (4) reasons; (5) whether it is the first instance; (6) the period since when it has been continuing; (7) corrective measures taken, including any action or direction by any regulatory authority; (8) whether it continues on the date of reporting; and (9) if so, the expected timeline and corrective measures envisaged.
Does the circular change the duty to report non-compliance immediately?
No. The Compliance Officer must still immediately and independently report any non-compliance observed, under Regulation 31 — a duty in place since the 2020 Regulations. The circular only prescribes the format for the quarterly report.
When did the reporting format come into force?
With immediate effect from 12 November 2026. The circular was issued under sections 12 and 13 of the IFSCA Act, 2019, read with regulation 78 of the IFSCA (Bullion Market) Regulations, 2025.
Sources
- Primary source — IFSCA Circular IFSCA-PMTS/10/2023-Precious Metals/2026/8 dated 12 November 2026, "Format for reporting of non-compliance(s) under the IFSCA (Bullion Market) Regulations, 2025" (official PDF): https://ifsca.gov.in/CommonDirect/GetFileView?id=850da50e42b9c192894a42a7d2dee585&fileName=Circular_on_Format_for_reporting_of_non_compliance_s__12th_November_2026_20261112_0500.pdf
- IFSCA — New Section listing (official): https://ifsca.gov.in/Home/NewSection
- Related reading — IFSCA Good Delivery Guidelines, 15 October 2026: https://www.corplawupdates.in/updates/ifsca-good-delivery-guidelines-2026
- Related reading — IFSCA framework for Self Clearing Corporations and bullion trading members, 27 October 2026: https://www.corplawupdates.in/updates/ifsca-ends-direct-iibx-trading-scc-bullion-trading-members
This article is based solely on IFSCA Circular IFSCA-PMTS/10/2023-Precious Metals/2026/8 dated 12 November 2026 and on Regulation 31 of the IFSCA (Bullion Market) Regulations, 2025 and regulation 24(2) of the IFSCA (Bullion Exchange) Regulations, 2020 as quoted in that circular. No first quarterly deadline date has been stated, because the circular gives only the 45-calendar-day rule.
