RBI Updates Risk Management Master Direction for SPDs and Reporting
Current · Source: Reserve Bank of India · RBI/2024-25/32 · issued 03 May 2024 · ~2 min read
Quick answerRBI has amended the Master Direction on Risk Management and Inter-Bank Dealings to include Standalone Primary Dealers (SPDs) as Authorised Dealers Category-III under FEMA, and updated OTC derivative reporting rules to CCIL's Trade Repository. Effective immediately.
The rule, in the simplest words
Standalone Primary Dealers (SPDs) are now officially allowed to deal in foreign exchange and foreign currency derivatives, just like banks.
Banks and SPDs must report all over-the-counter (OTC) foreign exchange and foreign currency interest rate derivative contracts to CCIL's Trade Repository (a central database) within strict time limits.
For trades between banks involving Indian rupees (except currency swaps and complex derivatives), report every hour within 30 minutes after the hour ends.
For trades with customers (like companies or individuals), report by 12 noon the next business day.
Banks are responsible for making sure the trade details they report are correct, even if the other party doesn't report anything.
How it plays out — a real example
Ravi, a forex & trade-finance officer in Indore, now has to check that his bank's derivative trades are reported on time. Yesterday, his bank did a currency swap with a client at 4 p.m. Ravi reminds the team to report it to CCIL's Trade Repository before 12 noon the next day, following the new rule.
What changed
Standalone Primary Dealers (SPDs) are now formally included as Authorised Dealers Category-III under the Master Direction, with specific compliance requirements. Reporting directions for OTC foreign exchange and foreign currency interest rate derivative contracts to CCIL's Trade Repository have been updated, including format, mode, and timelines.
What it means for you
Banks and SPDs must align their derivative operations with the revised Master Direction, ensuring SPDs follow applicable RBI directions. The updated reporting framework enhances transparency and regulatory oversight of OTC derivatives, requiring systems to meet new reporting standards.
What you must do
Review Annex I and II of the circular to understand specific amendments for SPDs and reporting changes.
Update internal policies and systems to reflect SPDs as Authorised Dealers Category-III under FEMA.
Ensure OTC derivative reporting to CCIL's Trade Repository complies with revised format, mode, and timelines.
Train relevant staff on the updated Master Direction, especially for SPD-related provisions.
Verify that all prior circulars listed in Appendix III are superseded and no longer applied.
Who it affects
Authorised Dealer Category-I banks, Standalone Primary Dealers (SPDs), Clearing Corporation of India Ltd. (CCIL)
❓ Common questions
What is the key change for Standalone Primary Dealers (SPDs)?
SPDs are now explicitly authorized as Authorised Dealers Category-III under FEMA, and must comply with the Master Direction on Risk Management and Inter-Bank Dealings, along with their specific Master Direction from 2016.
Are there any new reporting requirements for OTC derivatives?
Yes, directions for reporting OTC foreign exchange and foreign currency interest rate derivative contracts to CCIL's Trade Repository have been updated, including changes to format, mode, and timelines as per Annex II.
When do these changes take effect?
The amendments are effective immediately from May 3, 2024, and supersede earlier circulars listed in Appendix III of the Master Direction.
📜 Read the original circular — full text as issued by RBI
B. REPORTING TO THE TRADE REPOSITORY
(i) Authorised Dealers should report all OTC foreign exchange derivative contracts and foreign currency interest rate derivative contracts, undertaken by them directly or through their overseas entities 1 (including overseas branches, IFSC Banking Units, wholly owned subsidiaries and joint ventures of Authorised Dealers), to the Trade Repository (TR) of Clearing Corporation of India Ltd. (CCIL) as per the following timelines: Inter-bank foreign exchange derivative contracts involving INR (except currency swaps and structured derivatives) should be reported in hourly batches within 30 minutes from completion of the hour. Such contracts executed 30 minutes prior to closure of CCIL’s reporting platform for the day and subsequent to closure of CCIL’s reporting platform for the day should be reported by 10 a.m of the following business day;
Inter-bank foreign exchange derivative contracts not involving INR (except currency swaps and structured derivatives) executed up to 5 p.m. on any given day should be reported by 05:30 p.m of that day. Such contracts executed after 5 p.m should be reported by 10 a.m of the following business day;
Inter-bank currency swaps, structured derivatives and foreign currency interest rate derivative contracts executed upto 5 p.m. on any given day should be reported before closure of CCIL’s reporting platform for the day. Such contracts executed after 5 p.m should be reported by 10 a.m of the following business day; and
Foreign exchange derivative contracts and foreign currency interest rate derivative contracts executed with clients should be reported before 12 noon of the following business day.
Note: For the purpose of (a) (b) and (c), structured derivative shall have the meaning as assigned in the Master Direction – Reserve Bank of India (Market-makers in OTC Derivatives) Directions, 2021 dated September 16, 2021 , as amended from time to time.
(ii) Under the ‘back-to-back’ arrangement, trade details, including particulars of the non–resident client should be reported to the TR.
(iii) There shall be no requirement of matching transactions with overseas counterparties and client transactions in the TR as the overseas counterparties and clients are not required to report/confirm the transaction details. Authorised Dealers shall be responsible for ensuring the accuracy in respect of transactions reported.
(iv) Authorised Dealers should ensure that outstanding balances between their books and the TR are reconciled on an ongoing basis.
(v) The reporting formats shall be as indicated by CCIL with the prior approval of the Reserve Bank.
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2024-25/32 · issued 03 May 2024. The plain-English explanation above is BankPulse’s own independent summary.
Update internal policies and systems to reflect SPDs as Authorised Dealers Category-III under FEMA.
📜 Compliance
Review Annex I and II of the circular to understand specific amendments for SPDs and reporting changes.
Ensure OTC derivative reporting to CCIL's Trade Repository complies with revised format, mode, and timelines.
Train relevant staff on the updated Master Direction, especially for SPD-related provisions.
Verify that all prior circulars listed in Appendix III are superseded and no longer applied.
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 (Authorised Dealer Category-I banks, Standalone Primary Dealers (SPDs), Clearing Corporation of India Ltd. (CCIL)), your first concrete step on “RBI Updates Risk Management Master Direction for SPDs and Reporting” is: “Review Annex I and II of the circular to understand specific amendments for SPDs and reporting changes.” (RBI issued this 03 May 2024).
Circular: RBI/2024-25/32 -- RBI Updates Risk Management Master Direction for SPDs and Reporting
Issued: 03 May 2024
Action required: Review Annex I and II of the circular to understand specific amendments for SPDs and reporting changes.
Action required: Update internal policies and systems to reflect SPDs as Authorised Dealers Category-III under FEMA.
Action required: Ensure OTC derivative reporting to CCIL's Trade Repository complies with revised format, mode, and timelines.
Action required: Train relevant staff on the updated Master Direction, especially for SPD-related provisions.
Action required: Verify that all prior circulars listed in Appendix III are superseded and no longer applied.
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 03 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=12680&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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