HomeCirculars › RBI/2024-25/89

RBI Expands FX Reporting to Trade Repository

Current · Source: Reserve Bank of India · RBI/2024-25/89 · issued 08 Nov 2024 · ~2 min read
Quick answerRBI mandates reporting of FX spot, cash, and tom deals to CCIL's Trade Repository from Feb 10, 2025. Inter-bank deals have hourly batch timelines; client deals above USD 1 million from May 12, 2025, and above USD 50,000 from Nov 10, 2025, must be reported by next day noon.
The rule, in the simplest words
How it plays out — a real example

A forex & trade-finance officer in Indore, Priya, processes a client's FX spot deal worth USD 80,000 on November 15, 2025. She must report this deal to CCIL's Trade Repository by noon the next business day, using her bank's updated system that now tracks all deals above USD 50,000.

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

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

❓ Common questions

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.

📜 Read the original circular — full text as issued by RBI
RBI/2024-25/89 FMRD.MIOD.07/02.05.002/2024-25 November 08, 2024 To, All Authorised Dealers Madam/Sir, Reporting of Foreign Exchange Transactions to Trade Repository Please refer to the Master Direction – Risk Management and Inter-Bank Dealings dated July 5, 2016 , as amended from time to time, which requires, inter-alia, Authorised Dealers to report all over-the-counter (OTC) foreign exchange derivative contracts and foreign currency interest rate derivative contracts, undertaken by them directly or through their overseas entities (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). 2. To ensure completeness of transaction data in TR for all foreign exchange instruments, it has been decided to expand the reporting requirement to include foreign exchange spot (including value cash and value tom) deals in a phased manner. Accordingly, transactions in the following foreign exchange contracts, involving INR or otherwise, (hereinafter referred to as “FX contracts”) shall now be reported to the TR: foreign exchange cash; foreign exchange tom; and foreign exchange spot. Note: Money changing transactions are not in the scope of these Directions and shall be governed by the Master Direction – Money Changing Activities dated January 01, 2016 , as amended from time to time, or any other rule, regulation or Direction issued in this regard. 3. Authorised Dealers shall report all inter-bank FX contracts undertaken by them to the TR of CCIL with effect from February 10, 2025 as per the following timelines: Inter-bank FX contracts involving INR shall be reported in hourly batches within 30 minutes from completion of the hour. Such contracts executed 60 minutes prior to closure of CCIL's reporting platform for the day and subsequent to closure of CCIL's reporting platform for the day shall be reported by 10 a.m. of the following business day. Inter-bank FX contracts not involving INR executed up to 5 p.m. on any given day should be reported by 5:30 p.m. of that day. Such contracts executed after 5 p.m. should be reported by 10 a.m. of the following business day. 4. Authorised Dealer shall report all FX contracts executed with clients to the TR of CCIL in a phased manner. The following FX contracts executed with clients shall be mandatorily reported as per the following timelines: FX contracts with the value equal to or exceeding the threshold limit of USD 1 million and equivalent thereof in other currencies with effect from May 12, 2025. FX contracts with the value equal to or exceeding the threshold limit of USD 50,000 and equivalent thereof in other currencies with effect from November 10, 2025. FX contracts executed with clients should be reported before 12 noon of the following business day. 5. 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 Dealer shall be responsible for ensuring the accuracy in respect of transactions reported. 6. Authorised Dealer shall ensure that outstanding balances between their books and the TR are reconciled and subjected to concurrent audit on an ongoing basis. 7. The reporting formats shall be as indicated by CCIL with the prior approval of the Reserve Bank. 8. For the purpose of these Directions, Authorised Dealer shall have the same meaning assigned in the Master Direction – Risk Management and Inter-Bank Dealings dated July 5, 2016 , as amended from time to time. 9. These directions are issued under the powers vested in the Reserve Bank of India under Section 45W of the Reserve Bank of India Act, 1934 and Sections 10(4), 11(1) and 11(2) of the Foreign Exchange Management Act, 1999 and are without prejudice to permissions/approvals, if any, required under any other law. Yours faithfully, (Dimple Bhandia) Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2024-25/89 · issued 08 Nov 2024. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Who does what — compliance checklist
⚙️ Operations
  • Set up reconciliation and concurrent audit processes for outstanding balances between your books and the TR.
💻 IT / Systems
  • Update systems to capture and report FX spot, cash, and tom deals to CCIL's TR by February 10, 2025.
📜 Compliance
  • 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.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template

Example: if you are an IT/Systems lead at a bank this circular applies to (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), your first concrete step on “RBI Expands FX Reporting to Trade Repository” is: “Update systems to capture and report FX spot, cash, and tom deals to CCIL's TR by February 10, 2025.” (RBI issued this 08 Nov 2024).

  1. Circular: RBI/2024-25/89 -- RBI Expands FX Reporting to Trade Repository
  2. Issued: 08 Nov 2024
  3. Action required: Update systems to capture and report FX spot, cash, and tom deals to CCIL's TR by February 10, 2025.
  4. Action required: 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.
  5. Action required: 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.
  6. Action required: Set up reconciliation and concurrent audit processes for outstanding balances between your books and the TR.
  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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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=12748&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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