HomeCirculars › RBI/2012-13/185

RBI Allows QFIs to Hedge Currency Risk on Investments

Current · Source: Reserve Bank of India · RBI/2012-13/185 · issued 31 Aug 2012 · ~2 min read
Quick answerRBI now permits Qualified Foreign Investors (QFIs) to hedge currency risk on their equity and debt investments in India using forwards, options, and swaps. This covers market value of holdings and IPO-related flows under ASBA, with guidelines on eligibility, rollover, and cost.
The rule, in the simplest words
How it plays out — a real example

A forex & trade-finance officer in Indore, Priya, helps a QFI client who invested ₹10 crore in Indian stocks. She sets up a forward contract to lock in the rupee-dollar rate for that amount, and every quarter she reviews the investment value to ensure the hedge still covers it, following the new RBI rules.

What changed

Previously, QFIs could invest in rupee-denominated mutual funds, equities, and debt securities, but hedging guidelines were not fully detailed. Now, RBI has explicitly allowed QFIs to hedge currency risk on permissible investments using forward contracts, foreign currency-INR options, and swaps for IPO flows. The circular provides operational guidelines, including eligibility based on investment value, quarterly reviews, and rules for naked hedges and rollovers.

What it means for you

For banks acting as AD Category-I, this expands the derivative product suite for QFI clients, enabling them to manage rupee volatility. Banks must now set up processes to verify underlying exposures quarterly and handle hedge cancellations and rollovers per RBI rules. This could increase demand for forex hedging services from QFIs, boosting fee income but requiring robust compliance.

What you must do

Who it affects

AD Category-I banks, Qualified Foreign Investors (QFIs), Qualified Depository Participants (QDPs), Mutual funds and listed companies with QFI investments

❓ Common questions

What hedging products are now available for QFIs?

QFIs can use forward foreign exchange contracts (INR as one leg), foreign currency-INR options, and for IPO-related flows, foreign currency-INR swaps.

How often must banks review the underlying exposure for QFI hedges?

AD Category-I banks must review the investment value at least quarterly, based on market price movements, fresh inflows, and repatriations, to ensure the hedge is supported by actual exposure.

Can a QFI rebook a cancelled hedge contract?

No, once a forward contract is cancelled, it cannot be rebooked. However, contracts can be rolled over on or before maturity.

📜 Read the original circular — full text as issued by RBI
RBI/2012-13/185 A. P. (DIR Series) Circular No. 21 August 31, 2012 To       All Category-I Authorised Dealer Banks Madam / Sir, Foreign investment by Qualified Foreign Investors (QFIs) – Hedging facilities Attention of Authorized Dealers Category – I (AD Category – I) banks is invited to the Foreign Exchange Management (Foreign Exchange Derivative Contracts) Regulations, 2000 dated May 3, 2000 [ Notification No. FEMA/25/RB-2000 dated May 3, 2000 ] and A.P. (DIR Series) Circular No.32 dated December 28, 2010 , as amended from time to time. 2. In terms of A.P. (DIR Series) Circular No.8 dated August 9, 2011 , A.P. (DIR Series) Circular No. 42 dated November 3, 2011 , A.P. (DIR Series) Circular No. 66 dated January 13, 2012 and A.P. (DIR Series) Circular No. 89 dated March 1, 2012 , Qualified Foreign Investors (QFI) are allowed to invest in rupee denominated units of domestic Mutual Funds and listed equity shares  and allowing SEBI registered FIIs to invest in to be listed debt securities subject to the terms and conditions mentioned therein. Further, in terms of A.P. (DIR Series) Circular No. 7 dated July 16, 2012 , Qualified Foreign Investors (QFIs) have been permitted to purchase on repatriation basis debt securities subject to the various terms and conditions. As per para 2(x) of the circular, QFIs would be permitted to hedge their currency risk on account of their permissible investments (in equity and debt instruments) in terms of the guidelines issued by the Reserve Bank from time to time. 3. It has now been decided to allow QFIs to hedge their currency risk on account of their permissible investments (in equity and debt instruments), as per the details given in the Annex . 4. Necessary amendments to the Notification No. FEMA.25/RB-2000 dated May 3, 2000 [Foreign Exchange Management (Foreign Exchange Derivative Contracts) Regulations, 2000] are being notified separately. 5. AD Category - I banks may bring the contents of this circular to the notice of their constituents and customers. 6. The directions contained in this circular have been issued under sections 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, (Rudra Narayan Kar) Chief General Manager Annex [Annex to A.P. DIR Circular No.21 dated August 31 , 2012] Facilities for Qualified Foreign Investors (QFIs) Purpose To hedge the currency risk on the market value of entire investment in equity and/or debt in India as on a particular date. To hedge Initial Public Offers (IPO) related transient capital flows under the Application Supported by Blocked Amount (ASBA) mechanism. Products Forward foreign exchange contracts with rupee as one of the currencies and foreign currency-INR options. Foreign Currency – INR swaps for IPO related flows. Operational Guidelines, Terms and Conditions QFIs are allowed to hedge the currency risk on account of their permissible investments with the AD Category-I bank with whom they are maintaining the Rupee Account opened for the purpose of investment. The eligibility for cover may be determined on the basis of the declaration of the QFI with periodic review undertaken by the AD Category I bank based on the investment value as provided / certified by QDP of the QFI at least at quarterly intervals, on the basis of market price movements, fresh inflows, amounts repatriated and other relevant parameters to ensure that the forward cover outstanding is supported by underlying exposures. If a hedge becomes naked in part or in full owing to contraction of the market value of the portfolio, for reasons other than sale of securities, the hedge may be allowed to continue till the original maturity, if so desired. The contracts, once cancelled cannot be rebooked. The forward contracts may, however, be rolled over on or before maturity. The cost of hedge should be met out of repatriable funds and /or inward remittance through normal banking channel. All outward remittances incidental to the hedge are net of applicable taxes. For IPO related transient capital flows QFIs can undertake foreign currency- rupee swaps only for hedging the flows relating to the IPO under the ASBA mechanism. The amount of the swap should not exceed the amount proposed to be invested in the IPO. The tenor of the swap should not exceed 30 days. The contracts, once cancelled, cannot be rebooked. Rollovers under this scheme will also not be permitted.
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2012-13/185 · issued 31 Aug 2012. The plain-English explanation above is BankPulse’s own independent summary.
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Worked example & action-note template

Example: if you are a Compliance officer at a bank this circular applies to (AD Category-I banks, Qualified Foreign Investors (QFIs), Qualified Depository Participants (QDPs), Mutual funds and listed companies with QFI investments), your first concrete step on “RBI Allows QFIs to Hedge Currency Risk on Investments” is: “Update internal policies to allow QFIs to hedge currency risk using forwards, options, and swaps as per the circular.” (RBI issued this 31 Aug 2012).

  1. Circular: RBI/2012-13/185 -- RBI Allows QFIs to Hedge Currency Risk on Investments
  2. Issued: 31 Aug 2012
  3. Action required: Update internal policies to allow QFIs to hedge currency risk using forwards, options, and swaps as per the circular.
  4. Action required: Establish quarterly review mechanisms to verify QFI investment values and ensure hedge coverage matches underlying exposures.
  5. Action required: Train staff on handling IPO-related swaps under ASBA and rules for naked hedges, cancellations, and rollovers.
  6. Action required: Communicate these hedging facilities to QFI clients and ensure all outward remittances are net of applicable taxes.
  7. Owner: ____________ Target date: ____________
  8. Board/committee approval needed? Y / N
  9. 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.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=7537&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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