Seven FEMA circulars — five of them tied to India's External Commercial Borrowings framework — have formally been taken off the Reserve Bank's active rulebook, even though most had already stopped mattering years ago. The September 8, 2026 circular is less about changing the law and more about tidying it up: it removes references that newer directives had long since overtaken.
Quick answer
The Reserve Bank of India, through A.P. (DIR Series) Circular No. 21 dated September 8, 2026 (RBI/2026-27/254), has withdrawn seven circulars issued under the Foreign Exchange Management Act, 1999. The withdrawal is part of a comprehensive review of FEMA circulars issued since June 1, 2000, aimed at removing directives that have become redundant, overlapping, or superseded by newer regulations. Five of the seven withdrawn circulars relate to External Commercial Borrowings; the other two cover Money Transfer Service Scheme sub-agents and rupee borrowing by non-residents.
A.P. (DIR Series) circulars are how the RBI issues day-to-day directions to Authorised Persons — mainly banks authorised to deal in foreign exchange — under FEMA. Over the years, some of these circulars get overtaken by newer rules but are never formally taken off the books. This circular is RBI's way of cleaning that up: it declares seven such circulars withdrawn, rather than leaving them technically "in force" while practically dead.
Which seven circulars are being withdrawn?
All seven were superseded, made redundant, or overtaken by overlap with newer directives, per the RBI's own description.
Why this matters
None of these seven circulars is described as still governing live transactions — RBI's own language is that they "have ceased to be operative owing to subsequent regulatory amendments, redundancy, overlap or supersession by newer directives." The practical effect on day-to-day ECB or remittance activity should therefore be minimal, since compliant Authorised Persons and borrowers are already following the current framework. What this circular does change is the reference list: any compliance manual, legal opinion, training material or internal SOP that still cites Circular No. 17 of 2015, No. 25 of 2014, No. 85 of 2014, No. 81 of 2013, No. 119 of 2013, No. 49 of 2012 or No. 48 of 2012 as an active source is now citing a withdrawn circular.
Who is affected?
All Authorised Persons — banks and entities authorised to deal in foreign exchange.
Compliance, legal and treasury teams whose manuals or opinions cite any of the seven withdrawn circulars.
Transactions already concluded under the withdrawn circulars while they were in force.
Constituents of Authorised Persons, who "may" be informed of this circular at the AP's discretion.
The circular is dated September 8, 2026 and does not set out a separate "come into force" clause; the withdrawal takes effect from the date of the circular. It does not state any retrospective effect on transactions concluded under the seven circulars while they were operative.
Practical implications
For most Authorised Persons, this circular calls for a documentation audit rather than an operational change. Compliance and legal teams should search internal manuals, ECB compliance checklists, and training material for any of the seven circular numbers and update those references to point to the current, consolidated FEMA and ECB framework. Entities that operate under the Money Transfer Service Scheme should specifically check whether their sub-agent documentation still cites the withdrawn 2012 circular. Because RBI describes the review of FEMA circulars issued since June 1, 2000 as ongoing, this is unlikely to be the last such withdrawal — compliance teams tracking the FEMA framework should expect similar housekeeping circulars to follow.
Compliance checklist
Frequently asked questions
What does this RBI circular do?
It formally withdraws seven circulars issued under FEMA, 1999, that had already ceased to be operative due to subsequent amendments, redundancy, overlap or supersession by newer directives.
Why is RBI withdrawing circulars that were already inoperative?
This forms part of a comprehensive, ongoing review of FEMA circulars issued since June 1, 2000, aimed at rationalising the regulatory framework and removing dead references from the rulebook.
Which circulars have been withdrawn?
Seven A.P. (DIR Series) circulars dated between November 2012 and September 2015 — five relating to External Commercial Borrowings, one on Money Transfer Service Scheme sub-agents, and one on rupee borrowing by non-residents. The full list appears in the table above.
Does this withdrawal change any current ECB or FEMA rules?
No. The circular does not introduce new rules — it removes references to circulars RBI itself describes as already inoperative.
Does this affect transactions already completed under the withdrawn circulars?
The circular does not state any retrospective effect on past transactions; it withdraws the circulars from RBI's current active list going forward.
Who must act on this circular?
Primarily Authorised Persons — banks and entities authorised to deal in foreign exchange — who may bring its contents to the notice of their constituents.
When does the withdrawal take effect?
The circular is dated September 8, 2026 and does not specify a separate compliance date; the withdrawal takes effect from that date.
Under what legal authority was this circular issued?
Under Section 10(4) and Section 11(1) of the Foreign Exchange Management Act, 1999, without prejudice to permissions or approvals required under any other law.
Will more circulars be withdrawn in the future?
RBI describes this as part of an ongoing, comprehensive review of circulars issued since June 1, 2000, so further withdrawals under this initiative are possible, though this circular does not commit to any specific future action.
CorpLawUpdates analysis
Housekeeping circulars like this one rarely change what a compliant Authorised Person does day to day, but they matter for a different reason: legal research, audit trails and training material all suffer when a rulebook carries circulars that are technically live but practically dead. Formally withdrawing them removes that ambiguity. One gap worth flagging — the circular does not map each of the seven withdrawn circulars to the specific "newer directive" that superseded it, so a practitioner needing the current position on any of these topics (say, ECB in Indian Rupees, or Money Transfer Service Scheme sub-agents) will need to independently locate the current master direction or regulation that now governs it. Given RBI's stated intention to keep reviewing circulars issued since June 2000, compliance teams should treat this as the first of what may be several such withdrawal notices.
Document: RBI Circular — Review of Circulars issued under Foreign Exchange Management Act, 1999 (FEMA)
Issuing authority: Reserve Bank of India, Foreign Exchange Department, Central Office
Reference number: RBI/2026-27/254; A.P. (DIR Series) Circular No. 21
Date: September 8, 2026
Signatory: Dr. Aditya Gaiha, Chief General Manager-in-Charge
This article is for informational and educational purposes only and does not constitute legal or regulatory advice. Readers should verify the applicable primary regulatory source before taking action.
