What changed
RBI has expanded reporting requirements for foreign exchange transactions to include FX spot, cash, and tom deals, moving beyond just derivatives. Inter-bank FX contracts must be reported to CCIL's Trade Repository from February 10, 2025, with specific hourly batch timelines. Client FX contracts will be reported in phases: those equal to or above USD 1 million from May 12, 2025, and those equal to or above USD 50,000 from November 10, 2025, with a next-day noon deadline.
What it means for you
Banks must now report a broader set of FX transactions, including spot deals, to the Trade Repository, increasing operational load and requiring system upgrades. The phased client reporting thresholds mean banks need to track deal sizes and ensure timely reporting, with no matching requirement for overseas counterparties or clients. Concurrent audit and reconciliation of outstanding balances are now mandatory, raising compliance stakes.
What you must do
- Update systems to capture and report FX spot, cash, and tom deals to CCIL's TR by February 10, 2025.
- Implement hourly batch reporting for inter-bank INR FX contracts within 30 minutes of the hour, and for non-INR contracts by 5:30 PM same day or 10 AM next day.
- Prepare for phased client reporting: start tracking deals >= USD 1 million from May 12, 2025, and >= USD 50,000 from November 10, 2025, with next-day noon deadlines.
- Set up reconciliation and concurrent audit processes for outstanding balances between your books and the TR.
Who it affects
All Authorised Dealers (banks), Overseas branches, IFSC Banking Units, subsidiaries, and joint ventures of Authorised Dealers, Treasury and compliance teams handling FX transactions, CCIL (Clearing Corporation of India Ltd.) as Trade Repository operator
What is the deadline for reporting inter-bank FX contracts not involving INR?
Inter-bank FX contracts not involving INR executed up to 5 PM on any day must be reported by 5:30 PM that day. Contracts executed after 5 PM must be reported by 10 AM the following business day.
Are money changing transactions covered under this reporting requirement?
No, money changing transactions are explicitly excluded and continue to be governed by the Master Direction on Money Changing Activities dated January 1, 2016.
Do overseas counterparties or clients need to report or confirm transactions in the TR?
No, there is no requirement for matching transactions with overseas counterparties or clients. The Authorised Dealer is solely responsible for ensuring accuracy of reported transactions.