RBI allows bank guarantees for commodity hedging margins
Current · Source: Reserve Bank of India · RBI/2008-09/277 · issued 10 Nov 2008 · ~1 min read
Quick answerRBI now permits AD Category-I banks to issue standby LCs or bank guarantees for margin payments on approved commodity hedging, instead of direct remittances. This gives resident entities more flexibility in meeting overseas payment obligations.
The rule, in the simplest words
Banks can now issue a guarantee (a promise to pay if the customer doesn't) or a standby letter of credit (a special promise to pay) for margin payments (money kept aside as security) on commodity hedging (buying contracts to protect against price changes), instead of sending cash directly.
This rule only applies when the payment is already allowed by the bank's own permission or by a special approval from RBI for overseas (outside India) commodity hedging.
The bank must have a board-approved policy (a plan agreed by top managers) that says how much risk the bank can take for these guarantees, and treat them as part of the customer's credit limit (how much loan the customer can get).
The bank must assign risk weights (a number that shows how risky the guarantee is) for capital adequacy (having enough money to cover losses), following the usual rules.
How it plays out — a real example
A forex & trade-finance officer in Indore has a corporate customer who needs to pay margin money for hedging gold prices on an overseas exchange. Instead of asking the customer to send cash directly, the officer issues a bank guarantee for the margin amount, following the bank's board-approved policy and checking the customer's credit limit. This saves the customer from tying up cash, and the officer feels satisfied offering a flexible, non-funded solution.
What changed
Previously, banks could only make direct remittances for payment obligations from commodity derivative contracts. Now, AD Category-I banks can issue guarantees or standby letters of credit for these specific payments, subject to conditions in the circular's annex.
What it means for you
Banks can offer non-funded facilities like guarantees for margin payments on commodity hedging, reducing the need for customers to tie up cash. This expands product offerings but requires strict adherence to board-approved policies, credit exposure limits, and risk-weighting for capital adequacy.
What you must do
Ensure guarantees/standby LCs are issued only for remittances covered under delegated authority or specific RBI approval for overseas commodity hedging.
Adopt a board-approved policy defining the nature and extent of exposures for such transactions, treating them as part of customer credit exposure.
Assign appropriate risk weights for capital adequacy as per extant norms.
Verify compliance with overseas commodity hedging guidelines and ensure broker's month-end reports are submitted and verified for physical exposure backing.
Who it affects
AD Category-I banks, Resident entities with overseas commodity hedging payment obligations, Corporate treasuries involved in commodity derivative contracts
❓ Common questions
Can we issue a guarantee for any amount related to commodity hedging?
No, the guarantee or standby LC amount cannot exceed the margin payments made to the specific counterparty during the previous financial year.
What is the maximum tenure for such guarantees?
The guarantee or standby LC can be issued for a maximum period of one year, after marking a lien on the customer's non-funded facility limit.
Do we need to verify physical exposure backing for offshore positions?
Yes, you must regularly verify broker's month-end reports to ensure all offshore positions are backed by physical exposures.
📜 Read the original circular — full text as issued by RBI
RBI/2008-09/277
A.P. (DIR Series) Circular No.35
November 10, 2008
To
All Category - I Authorised Dealer Banks
Madam / Sir,
Remittance related to Commodity Derivative Contract
Issuance of Standby Letter of Credit / Bank Guarantee
Attention of Authorised Dealer Category - I (AD Category-I) banks is invited to Regulation 8 of Notification No.FEMA.25/2000-RB dated May 3, 2000 viz. Foreign Exchange Management (Foreign exchange derivative contracts) Regulations, 2000, as amended from time to time, regarding remittance of foreign exchange related to commodity derivative contract undertaken in accordance with the regulations.
2. The Reserve Bank has been receiving requests from banks for issuance of bank guarantee / standby letter of credit, in lieu of making a direct remittance towards payment obligations arising out of commodity derivative transactions entered into by customers with overseas counterparties. With a view to providing greater flexibility to resident entities who have such payment obligations related to commodity derivative contracts, it has been decided that AD Category-I banks may issue guarantees / standby letters of credit to cover these specific payment obligations subject to the conditions / guidelines given in the Annex to this Circular.
3. AD Category-I banks may issue guarantees / standby letters of credit only where the remittance is covered under the delegated authority or under the specific approval granted for overseas commodity hedging by the Reserve Bank.
4. The issuing bank shall have a Board approved policy on the nature and extent of exposures that the bank can take for such transactions and should be part of the credit exposure on the customers. The exposure should also be assigned risk weights, for capital adequacy purposes as per the extant provisions.
5. AD Category-I banks may bring the contents of this circular to the notice of their constituents concerned.
6. Necessary amendments to the Notification No.FEMA.8/2000-RB dated May 3, 2000 viz. Foreign Exchange Management (Guarantees) Regulations, 2000, is being issued separately.
7. The directions contained in this circular have been issued under Section 10(4) and 11(1) of the Foreign Exchange Management Act, 1999 (42 of 1999) and are without prejudice to permissions / approvals, if any, required under any other law.
Yours faithfully,
Salim Gangadharan
Chief General Manager-in-Charge
ANNEX
[Annex to A.P.(DIR Series) Circular No.35
dated November 10, 2008]
Conditions / Guidelines for issuance of standby letter of credit /
bank guarantee - commodity hedging transactions
1. The standby letter of credit / bank guarantee may be issued for the specific purpose of payment of margin money in respect of approved commodity hedging activities of the company.
2. The standby letter of credit / bank guarantee may be issued for an amount not exceeding the margin payments made to the specific counterparty during the previous financial year.
3. The standby letter of credit / bank guarantee may be issued for a maximum period of one year, after marking a lien on the non-funded facility available to the customer (letter of credit / bank guarantee limit).
4. The bank shall ensure that the guidelines for overseas commodity hedging have been duly complied with.
5. The bank shall ensure that broker's month-end reports duly confirmed / countersigned by corporate's financial controller have been submitted.
6. Brokers' month end reports shall be regularly verified by the bank to ensure that all off-shore positions are / were backed by physical exposures.
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2008-09/277 · issued 10 Nov 2008. The plain-English explanation above is BankPulse’s own independent summary.
Assign appropriate risk weights for capital adequacy as per extant norms.
📜 Compliance
Ensure guarantees/standby LCs are issued only for remittances covered under delegated authority or specific RBI approval for overseas commodity hedging.
Adopt a board-approved policy defining the nature and extent of exposures for such transactions, treating them as part of customer credit exposure.
Verify compliance with overseas commodity hedging guidelines and ensure broker's month-end reports are submitted and verified for physical exposure backing.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template
Example: if you are a Compliance officer at a bank this circular applies to (AD Category-I banks, Resident entities with overseas commodity hedging payment obligations, Corporate treasuries involved in commodity derivative contracts), your first concrete step on “RBI allows bank guarantees for commodity hedging margins” is: “Ensure guarantees/standby LCs are issued only for remittances covered under delegated authority or specific RBI approval for overseas commodity hedging.” (RBI issued this 10 Nov 2008).
Circular: RBI/2008-09/277 -- RBI allows bank guarantees for commodity hedging margins
Issued: 10 Nov 2008
Action required: Ensure guarantees/standby LCs are issued only for remittances covered under delegated authority or specific RBI approval for overseas commodity hedging.
Action required: Adopt a board-approved policy defining the nature and extent of exposures for such transactions, treating them as part of customer credit exposure.
Action required: Assign appropriate risk weights for capital adequacy as per extant norms.
Action required: Verify compliance with overseas commodity hedging guidelines and ensure broker's month-end reports are submitted and verified for physical exposure backing.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.
💬 Banker Discussion
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
BankPulse Compliance Evidence Pack — generated 05 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=4625&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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