RBI Ends Two Legacy Reporting Requirements for Rupee Accounts of Non-Resident Banks
The Reserve Bank of India has removed two long-standing reporting requirements relating to Rupee accounts of non-resident banks. The change was issued through RBI/2026-27/251, A.P. (DIR Series) Circular No. 20, dated September 2, 2026, and is addressed to all Authorised Dealer Category-I banks.
The circular is a targeted compliance simplification under the foreign-exchange framework. It does not introduce a new return or a new limit; instead, it discontinues two reporting obligations that had been carried forward from A.P. (DIR Series) Circular No. 92 dated April 4, 2003.
Two reporting requirements have been dispensed with
RBI refers specifically to paragraph B.2(ii) and paragraph B.8(i) of Part B of the 2003 circular. Under those provisions, Authorised Dealer banks were required to perform two separate reporting actions.
First, a bank had to furnish to the Central Office of RBI an up-to-date list of all its offices or branches maintaining Rupee accounts of non-resident banks. The list was to reflect the position at the end of December each year and had to be submitted before January 15 of the following year.
Second, banks had to report temporary overdrawals by overseas branches or correspondents when those overdrawals exceeded the permissible limit and were not adjusted within five days.
RBI says that, after a review, both of these reporting requirements are being dispensed with with immediate effect.
What changes for Authorised Dealer banks
The most visible change is removal of the annual January reporting task for the branch list and removal of the specific RBI Central Office report for temporary overdrawals that remained unadjusted beyond five days. Banks that maintain regulatory-return inventories should identify where these two obligations are embedded and update the applicable control descriptions, due-date calendars and responsibility matrices.
Because the first requirement used a recurring January 15 deadline, compliance teams should also check whether automated reminders, standard operating procedures or year-end checklists still trigger the legacy submission. Leaving an obsolete obligation active can create duplicate work and confusion over which report is legally required.
The circular is issued under FEMA powers
RBI states that the directions have been issued under sections 10(4) and 11(1) of the Foreign Exchange Management Act, 1999. It also makes clear that the circular is without prejudice to permissions or approvals that may be required under any other law.
That caveat matters. The September 2 circular should be read as removal of the two specified RBI reporting requirements, not as a blanket waiver of other foreign-exchange, account-operation, prudential or legal obligations that may apply to the underlying transactions or relationships.
Practical control points for finance and compliance teams
- Update the FEMA and Authorised Dealer compliance register to mark the two specified reports as discontinued from September 2, 2026.
- Remove or revise the annual January 15 reporting task for the list of branches maintaining Rupee accounts of non-resident banks.
- Review procedures dealing with overseas branch or correspondent overdrawals so teams understand which internal controls remain even though the specified RBI report has been removed.
- Retain the September 2 circular in the regulatory-change file to support future internal-audit or compliance testing of why the legacy reports were discontinued.
- Check for any other laws, approvals or internal risk limits that continue to apply, because RBI has expressly preserved those separate requirements.
Why the change is useful for banking and FEMA professionals
For CAs and finance professionals working in banks, treasury, correspondent banking or FEMA compliance, the circular is a useful example of regulatory rationalisation. The immediate benefit is lower legacy reporting burden, but the control challenge is to remove the discontinued obligations cleanly without weakening monitoring that remains necessary for account operations and risk management.
The practical takeaway: A.P. (DIR Series) Circular No. 20 removes two specific RBI reporting requirements with immediate effect. Authorised Dealer Category-I banks should update their reporting inventories and January compliance calendars, while continuing to observe any separate permissions, approvals and internal controls that remain applicable.
Official source: View the official source document
Key takeaway
RBI has immediately discontinued the annual branch-list submission and a specified temporary-overdraft report linked to Rupee accounts of non-resident banks, reducing two legacy FEMA reporting tasks for AD Category-I banks.
