The Reserve Bank of India removed two long-standing reporting obligations on Authorised Dealer Category-I banks in relation to Rupee accounts of non-resident banks, by A.P. (DIR Series) Circular No. 20 (RBI/2026-27/251) dated 2 September 2026. Both obligations dated from 2003. The circular is issued under sections 10(4) and 11(1) of the Foreign Exchange Management Act, 1999, and the relief takes immediate effect.
Background
The obligations removed sat in Para B.2(ii) and B.8(i) of Part B of A.P. (DIR Series) Circular No. 92 dated 4 April 2003, and the 2026 circular sets them out before dispensing with them.
Under the first, AD banks were required to furnish an up-to-date list of all their offices and branches maintaining Rupee accounts of non-resident banks, as at the end of December each year, to RBI's Central Office before 15 January of the following year. That is a static-inventory return: it told the central bank where, across a bank's branch network, vostro relationships were being maintained.
Under the second, AD banks were required to report to the Central Office temporary overdrawals by overseas branches or correspondents over the permissible limit, where those overdrawals were not adjusted within five days. That is an exception return: nothing was reported unless a limit was breached and the breach persisted beyond the short cure window.
Both are artefacts of a supervisory model built for paper and periodic returns. In 2003 a central bank had no other economical way to know which branches maintained foreign correspondent accounts, or which overdrawals had gone unadjusted, than to ask the bank to write it down once a year and to raise its hand when something went wrong.
Key provisions
The circular is four short paragraphs.
The recital. Paragraph 1 identifies Para B.2(ii) and B.8(i) of Part B of A.P. (DIR Series) Circular No. 92 dated 4 April 2003 and reproduces the two obligations — the annual list before 15 January, and the reporting of unadjusted temporary overdrawals over the permissible limit beyond five days.
The dispensation. Paragraph 2 states: "On a review, it has been decided to dispense with the above reporting requirements with immediate effect." That is the entire operative provision. RBI offers no further reason, and none is supplied here.
The statutory basis and saving. Paragraph 3 records that the directions are issued under sections 10(4) and 11(1) of the Foreign Exchange Management Act, 1999 (42 of 1999), and "are without prejudice to permissions/approvals, if any, required under any other law."
Addressees. The circular is addressed to all Authorised Dealer Category-I banks and is signed by a Chief General Manager of the Foreign Exchange Department.
Notably, the circular does not touch the substantive rules. The permissible limit on overdrawals is not changed, the five-day adjustment period is not changed as a matter of banking practice, and the conditions on maintaining Rupee accounts of non-resident banks are not changed. What has gone is the duty to tell RBI.
Implications for practitioners
The correct reading of a dispensation circular is narrow, and compliance teams get this wrong in a predictable direction: they delete the control along with the return.
The five-day adjustment norm for temporary overdrawals is the clearest example. A bank that was reporting unadjusted overdrawals to RBI necessarily had a mechanism for detecting them. That detection capability is now unreported, but it is not thereby unnecessary — the underlying limit and the expectation of prompt adjustment are untouched by this circular, and paragraph 3's saving for permissions and approvals under any other law makes clear that RBI is not clearing the field. Banks should retain the monitoring, retire only the filing, and record the distinction in the control documentation so that a later reviewer does not read the absence of a return as the absence of a rule.
The same applies to the branch inventory. Knowing which branches maintain non-resident bank Rupee accounts is not a reporting artefact; it is basic control information for sanctions screening, correspondent-banking risk assessment and audit scoping. The 15 January return was one consumer of that information, not its source. Removing the return should not disturb the register.
Two operational points follow. First, the immediacy of the change means there is no residual filing for the period ending December 2026 — the obligation is dispensed with as at 2 September 2026, and the circular provides for no final or transitional return. Compliance calendars carrying a 15 January item should be updated now, with the circular reference recorded against the closure so the deletion is auditable.
Second, internal policy documents that cite A.P. (DIR Series) Circular No. 92 of 4 April 2003 need review rather than deletion. Only two of that circular's paragraphs have been dispensed with; the rest of Part B stands. A policy that treats the 2003 circular as superseded in whole would overstate the change.
More broadly, this belongs to a recognisable pattern of periodic-return pruning. Where a supervisor obtains the same information through system-based collection, the standalone return becomes redundant and is withdrawn. Firms should expect that the disappearance of a return in that pattern is usually accompanied by continued — sometimes increased — data expectations elsewhere, and should not read individual dispensations as a reduction in supervisory visibility.
Frequently Asked Questions
Is a final return due for the period up to 2 September 2026?
The circular does not provide for one. Paragraph 2 dispenses with the reporting requirements with immediate effect and prescribes no transitional or final filing. Banks with an unfiled return covering an earlier period should form their own view on that legacy obligation; nothing in the 2 September 2026 circular addresses it.
Has the permissible limit on overdrawals by overseas branches changed?
No. A.P. (DIR Series) Circular No. 20 dated 2 September 2026 removes the obligation to report unadjusted temporary overdrawals over the permissible limit beyond five days. It does not alter the limit itself, nor the expectation that such overdrawals be adjusted.
Which banks does the circular apply to?
All Authorised Dealer Category-I banks. The circular is addressed to that class and issued under sections 10(4) and 11(1) of the Foreign Exchange Management Act, 1999, which govern directions to authorised persons.