FEMA Compounding: Max Penalty Capped at ₹2 Lakh for Minor Contraventions
Current · Source: Reserve Bank of India · RBI/FED/2025-26/32 · issued 24 Apr 2025 · ~2 min read
Quick answerRBI has capped the maximum compounding amount at ₹2,00,000 per regulation/rule for contraventions under row 5 of the FEMA compounding matrix, applicable from April 24, 2025. This provides relief for minor, exceptional cases.
The rule, in the simplest words
From April 24, 2025, the maximum fine for minor rule-breaking (called 'contraventions') under row 5 of the FEMA compounding matrix is capped at ₹2,00,000 (two lakh rupees) per rule.
This cap is only for small, special cases where the person in charge (compounding authority) decides it's fair based on the situation and public interest.
Banks and customers who broke a rule under row 5 can now pay at most ₹2 lakh, instead of a higher amount, but only if the authority agrees.
The cap is not automatic; the compounding authority must be satisfied that the case is exceptional and in wider public interest.
How it plays out — a real example
A forex & trade-finance officer in Indore discovers a customer accidentally exceeded the foreign exchange limit for a small overseas payment, falling under row 5 of the FEMA matrix. Instead of worrying about a huge penalty, the officer notes the exceptional circumstances and applies for compounding, knowing the maximum fine is now capped at ₹2 lakh, giving the customer relief and encouraging timely compliance.
What changed
RBI inserted a new clause (Para 5.4.II.vi) in the Master Directions on compounding of contraventions under FEMA, 1999. It allows the compounding authority to cap the maximum compounding amount at ₹2,00,000 per regulation/rule for contraventions under row 5 of the computation matrix, subject to satisfaction based on nature, exceptional circumstances, and wider public interest.
What it means for you
Banks and their customers facing minor FEMA contraventions under row 5 can now benefit from a reduced maximum penalty of ₹2 lakh, instead of potentially higher amounts. This provides a clear ceiling for such cases, reducing uncertainty and encouraging timely compounding. However, the cap is discretionary and applies only when the compounding authority deems it appropriate.
What you must do
Update internal FEMA compounding procedures to reflect the new ₹2 lakh cap for row 5 contraventions.
Train compliance staff to identify eligible cases under row 5 and document exceptional circumstances for cap consideration.
Advise customers with pending compounding applications about this potential relief and assist in submitting relevant details.
Monitor RBI updates to the Master Directions for any further changes to the compounding matrix.
Who it affects
All Authorised Dealer Category-I banks, Authorised banks, Customers/entities with FEMA contraventions under row 5 of the compounding matrix
❓ Common questions
What is row 5 of the FEMA compounding matrix?
The circular does not define row 5 explicitly, but it refers to a specific category of contraventions in the computation matrix under the Master Directions. Banks should refer to the Master Directions dated April 24, 2025 for the exact classification.
Does the ₹2 lakh cap apply automatically to all row 5 contraventions?
No, it is subject to the compounding authority's satisfaction based on the nature of contravention, exceptional circumstances, and wider public interest. It is not automatic.
When does this change take effect?
The circular was issued on April 24, 2025, and the Master Directions are updated accordingly from that date.
📜 Read the original circular — full text as issued by RBI
RBI/FED/2025-26/32
A.P. (DIR Series) Circular. No 04/2025-26
April 24, 2025
To,
All Authorised Dealer Category-I banks and Authorised banks
Madam / Sir,
Amendments to Directions - Compounding of Contraventions under FEMA, 1999
Attention of Authorised Dealer (AD) Category - I banks is invited to
Directions for compounding of contraventions under FEMA, 1999, issued vide A.P. (DIR Series) Circular No. 17/2024-25 dated October 1, 2024 and
Master Directions on compounding of contraventions under FEMA, 1999, dated April 22, 2025
2. On a review, it is decided that the following clause shall be inserted as Para 5.4.II.vi in aforementioned Master Directions.
“vi. Subject to satisfaction of the compounding authority, based on the nature of contravention, exceptional circumstances/ facts involved in case, and in wider public interest, the maximum compounding amount imposed may be capped at INR 2,00,000/- for contravention of each regulation/ rule (applied in a compounding application) with respect to contraventions under row 5 of the above computation matrix.”
3. The aforesaid Master Directions shall accordingly be updated to reflect the above change.
4. All AD Category-I banks and Authorised banks may bring the guidelines contained in this circular to the notice of their constituents.
5. 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/or without prejudice to permissions/approval, if any, required under any other law.
Yours faithfully,
(Dr. Aditya Gaiha)
Chief General Manager in Charge
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/FED/2025-26/32 · issued 24 Apr 2025. The plain-English explanation above is BankPulse’s own independent summary.
Advise customers with pending compounding applications about this potential relief and assist in submitting relevant details.
📜 Compliance
Update internal FEMA compounding procedures to reflect the new ₹2 lakh cap for row 5 contraventions.
Train compliance staff to identify eligible cases under row 5 and document exceptional circumstances for cap consideration.
Monitor RBI updates to the Master Directions for any further changes to the compounding matrix.
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 (All Authorised Dealer Category-I banks, Authorised banks, Customers/entities with FEMA contraventions under row 5 of the compounding matrix), your first concrete step on “FEMA Compounding: Max Penalty Capped at ₹2 Lakh for Minor Contraventions” is: “Update internal FEMA compounding procedures to reflect the new ₹2 lakh cap for row 5 contraventions.” (RBI issued this 24 Apr 2025).
Circular: RBI/FED/2025-26/32 -- FEMA Compounding: Max Penalty Capped at ₹2 Lakh for Minor Contraventions
Issued: 24 Apr 2025
Action required: Update internal FEMA compounding procedures to reflect the new ₹2 lakh cap for row 5 contraventions.
Action required: Train compliance staff to identify eligible cases under row 5 and document exceptional circumstances for cap consideration.
Action required: Advise customers with pending compounding applications about this potential relief and assist in submitting relevant details.
Action required: Monitor RBI updates to the Master Directions for any further changes to the compounding matrix.
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=12842&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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