Reference: RBI/2026-27/14 A.P. (DIR Series) Circular No. 07 dated 20 April 2026. Issued under the framework of the Master Direction on Risk Management and Inter-Bank Dealings dated 5 July 2016 (as amended), and read with A.P. (DIR Series) Circular No. 24 of 27 March 2025-26 and s.10(4), 11(1) & 11(2) FEMA, 1999.
Headline action — APDIR 03 of 1 April 2026 is withdrawn: The earlier circular which had imposed an absolute prohibition on Authorised Dealers offering Non-Deliverable Derivative (NDD) contracts involving INR is withdrawn by APDIR 07. In its place, APDIR 07 substitutes a calibrated framework that brings INR forex-derivative dealings back under the Master Direction's normal risk-management envelope, subject to the related-party restriction below.
Related-party restriction (the new substantive rule): Authorised Dealers are prohibited from undertaking foreign-exchange derivative contracts involving INR with related parties (intra-group entities — parent, subsidiary, sister concern). Two narrow exceptions: (i) cancellation / rollover of pre-existing contracts entered into before the circular date; and (ii) back-to-back transactions with non-related non-resident users.
Practical impact on group treasury: Intra-group hedging structures (e.g., Indian parent hedging USD receivable on a foreign subsidiary's books via an INR forward booked between two related-entity counterparties at an Indian AD bank) are out. Permitted: external hedges with unaffiliated non-resident counterparties, vanilla forward cover for the Indian entity's own forex exposure, deliverable forwards, and cross-currency swaps with non-related parties.
NRI / international client implications: NRI corporate clients with related-party derivative books should: (a) audit existing INR forex-derivative positions to identify related-party contracts; (b) for contracts maturing post-20 April 2026, allow them to run off — fresh related-party contracts cannot be booked; (c) where group treasury historically routed hedges through a single Indian AD entity for inter-company exposures, restructure to AD-vs-non-related-counterparty hedges; (d) document the related-party identification under the Master Direction's definition (typically Section 2(76) Companies Act / Ind AS 24 alignment).
Practice note: For audit clients in the listed-entity space, related-party derivative contracts also intersect with SEBI LODR Reg 23 material-RPT thresholds (lowered to ₹500 crore or 5% of consolidated turnover, whichever is lower, vide LODR Amendment Regulations 2026). Both Audit Committee approval and FEMA compliance now sit in the same review workflow — coordinate the secretarial/treasury/FEMA teams to avoid duplication or gaps.