RBI Allows Board Committee or Management Committee to Approve Form A2 Remittance Guidelines

Authorised Dealers can now have their Form A2 remittance guidelines approved by a Board Committee or Management Committee, not only by the Board itself. Under A.P. (DIR Series) Circular No. 23 dated 1 October 2026, the Reserve Bank of India has provided that these guidelines are to be framed with the approval of the Board or any Board Committee or Management Committee to which the Board has delegated powers. Board approval remains available, and the committee route depends on the Board having delegated the power. The change is narrow, but it affects who may sign off on a policy that governs outward forex remittances.

Quick Reference

What Changed?

Who Is Affected?

What Does the Circular Say?

• Para 1: Draws attention to para 3 of A.P. (DIR Series) Circular No. 12 dated July 03, 2024, under which ADs were advised to frame internal guidelines with Board approval for facilitating outward forex remittances on the basis of online or physical submission of Form A2 and other related documents.
• Para 2: States that, on a review, ADs "shall frame appropriate internal guidelines" with the approval of their Board or any Board Committee / Management Committee to which powers have been delegated by the Board.
• Para 3: All other instructions of Circular No. 12 remain unchanged. ADs may bring the circular to the notice of their constituents.
• Para 4: The directions are issued under sections 10(4) and 11(1) of FEMA, 1999 and are without prejudice to permissions or approvals required under any other law.

Two points of reading matter. First, para 2 uses "shall", so the obligation to frame internal guidelines is framed as mandatory, while the 2024 reference describes ADs as having been "advised". Second, the circular's subject line refers to the removal of limits on the amount of remittance, but the circular text itself states no limit and does not describe the content of Circular No. 12 beyond para 3. Readers should consult Circular No. 12 directly for the underlying framework. [INTERNAL LINK: RBI A.P. (DIR Series) Circular No. 12 dated July 03, 2024 on Form A2]

When Does It Apply?

In practice, ADs should treat the wider approval route as available from the date of the circular. The source does not describe any transition arrangement.

Practical Implications

In practice, this means that an AD can have its Form A2 remittance guidelines approved, or revised, through a Board-delegated committee, provided the Board has actually delegated that power. The circular does not say the delegation must be in writing, but a recorded Board resolution is the natural way to evidence it.

For compliance teams, the immediate issue is checking whether the existing delegation of powers covers this subject. The circular does not prescribe committee composition, and the expression "Management Committee" is not defined in it. ADs that do not wish to change anything can continue with Board approval.

Compliance Checklist

The circular is final. It prescribes no specific actions or dates, so the items below are editorial suggestions.

Frequently Asked Questions

What did RBI change in A.P. (DIR Series) Circular No. 23?

RBI decided that Authorised Dealers shall frame internal guidelines for Form A2 outward remittances with the approval of their Board or any Board Committee / Management Committee to which the Board has delegated powers. Under para 3 of Circular No. 12 dated July 03, 2024, ADs had been advised to frame such guidelines with the approval of their Board.

Which circular does it modify?

It refers to para 3 of A.P. (DIR Series) Circular No. 12 dated July 03, 2024. All other instructions of that circular remain unchanged.

Who must follow it?

The circular is addressed to all Authorised Dealers in Foreign Exchange. Its text refers to AD Category I banks and AD Category II entities.

Can a Management Committee approve the guidelines?

Yes, if the Board has delegated powers to that committee. The circular permits approval by any Board Committee or Management Committee to which powers have been delegated by the Board.

When does the change take effect?

The source states no separate effective date. The circular is dated October 01, 2026.

Does the circular set any remittance limit?

No. The circular states no limit, threshold or penalty. Its subject line, "Online submission of Form A2: Removal of limits on amount of remittance", is the same subject as Circular No. 12, but the circular does not describe the content of that framework beyond para 3.

Under what law is the circular issued?

It is issued under sections 10(4) and 11(1) of the Foreign Exchange Management Act, 1999 (42 of 1999), and is without prejudice to permissions or approvals required under any other law.

CorpLawUpdates Analysis

This is a governance change, not a change to the substance of the remittance framework. The practical benefit, in our assessment, is speed: where the Board has delegated the power, a Form A2 policy can be approved or revised by a committee without waiting for a Board meeting. The practical risk is documentation, since a committee approval is only as good as the delegation behind it. Practitioners should confirm the delegation exists and covers this subject before relying on a committee sign-off. The source does not indicate whether further similar amendments to other FEMA circulars are planned.