The Reserve Bank of India (RBI) has issued A.P. (DIR Series) Circular No. 15 (RBI/2026-27/144), dated June 19, 2026, addressed to all Authorised Dealer (AD) Category-I banks. The circular requires daily reporting of FCNR(B) deposits, External Commercial Borrowings (ECBs) and Overseas Foreign Currency Borrowings (OFCBs) mobilised under the two FMOD swap-facility circulars dated June 8, 2026, namely the swap facility for FCNR(B) deposits and the swap facility for ECBs and OFCBs.
Under this circular, AD Category-I banks must submit daily data — by 6 p.m. every day — on FCNR(B) deposits, ECBs and OFCBs mobilised under the Swap Facility, using three separate annexed formats sent to three distinct RBI email addresses. The circular also requires banks to back-report all transactions from June 8, 2026 (the date the underlying Swap Facility circulars were issued) up to the date of this direction, with this backdated data due alongside the first regular filing on June 22, 2026. The directions are issued under the Foreign Exchange Management Act (FEMA), 1999, and are signed by Dr. Aditya Gaiha, Chief General Manager-in-Charge.
Background: Why This Reporting Mandate Was Needed
On June 8, 2026, RBI's Financial Markets Operations Department (FMOD) issued two circulars introducing a Swap Facility mechanism for foreign-currency inflows. Since these swap facilities involve active monitoring of how much foreign currency is being mobilised through specific channels, RBI now needs real-time, granular reporting from the AD Category-I banks that execute these transactions on behalf of depositors and borrowers.
⚖️ Regulatory Foundation
What AD Category-I Banks Must Report
Paragraph 2 of the circular requires AD Category-I banks to submit daily data on three categories of foreign-currency mobilisation conducted under the FMOD Swap Facility circulars:
"All AD Category-I banks are advised to submit daily data on FCNR (B) deposits, External Commercial Borrowings (ECBs) and Overseas Foreign Currency Borrowings (OFCBs), mobilized under the provisions of the above FMOD circulars, by 6 p.m. every day."
Reporting Format and Designated Email IDs
The circular prescribes three distinct annexed formats, each to be emailed to a separate RBI division:
Daily Deadline and the NIL Statement Rule
Reports must reach RBI by 6 p.m. every day. Importantly, the obligation to report does not lapse on days without transactions — banks must still file a NIL statement on such days. The only exemption from daily filing is on Saturdays and holidays.
Backdated Reporting Requirement
Paragraph 3 requires banks to also report all FCNR(B), ECB and OFCB mobilisation data from June 8, 2026 (the date the underlying FMOD Swap Facility circulars were issued) up to the date these directions were issued. This catch-up data must be submitted together with the first regular reporting due on June 22, 2026.
Legal Basis Under FEMA, 1999
Paragraph 4 of the circular clarifies that these directions are issued under Sections 10(4), 11(1) and 11(2) of FEMA, 1999 (42 of 1999), and operate without prejudice to any other permissions or approvals required under any other law.
Reporting Position: Before vs After This Circular
Impact Analysis: Who Is Affected
Compliance Action Points
- Set up a daily reporting process for Annex I, II and III before 6 p.m.
- Assign ownership for NIL statement filing on transaction-free days
- Prepare and validate June 8–19, 2026 backdated data for the June 22, 2026 filing
- Document the new reporting SOP and circulate to treasury and forex desks
- Track adherence to the 6 p.m. daily cut-off and email IDs used
- Maintain audit trail of NIL statements and backdated submissions
- Tag all FCNR(B), ECB and OFCB transactions mobilised under the June 8, 2026 Swap Facility circulars
- Reconcile daily mobilisation figures before each day's 6 p.m. submission
- Coordinate with IT/MIS for automated Annex generation
- Advise clients raising ECB/OFCB under the Swap Facility that their AD bank now reports their mobilisation daily to RBI
- Ensure transaction documentation aligns with the bank's daily reporting timelines
Disclaimer: This article is for general informational purposes only and does not constitute legal or regulatory advice. Readers should refer to the original RBI circular and consult a qualified professional before taking any compliance action.
