TITLE: India's Reserve Bank Updates External Commercial Borrowing Reporting Requirements for Authorised Dealer Banks
BODY:
On March 30, 2026, the Reserve Bank of India (RBI) issued a circular updating reporting requirements for External Commercial Borrowing (ECB) under the Foreign Exchange Management Act, 1999. The circular, RBI/2025-26/253 A.P. (DIR Series) Circular No. 25, modifies existing directions contained in A.P. (DIR Series) Circular No. 16 dated September 30, 2022, and Part V and XIII of the Master Direction on Reporting under the Foreign Exchange Management Act, 1999.
The RBI introduced several key changes to ECB return submissions by Authorised Dealer Category I banks. Form ECB 1 and Revised Form ECB 1 shall now be treated as returns which do not capture flows, with late submission fees computed accordingly. Each delayed submission of Form ECB 2 return submitted under a separate Loan Registration Number shall be treated as a distinct instance for late submission fee calculation purposes. Designated Authorised Dealer Category I banks must submit complete returns received from eligible borrowers, along with due certification, to the RBI within seven calendar days from receipt. Late submission fees, where applicable, shall be payable to the relevant Regional Office of the RBI via NEFT (National Electronic Funds Transfer) or RTGS (Real Time Gross Settlement) following receipt of an acknowledgment email from the RBI. Designated Authorised Dealer Category I banks are responsible for monitoring payment of applicable late submission fees by their customers and constituents in cases of delayed return submissions.
These directions take effect from April 1, 2026. Authorised Dealer banks are required to communicate the circular's contents to their relevant customers and constituents. The directions are issued under sections 10(4), 11(1), and 11(2) of the Foreign Exchange Management Act, 1999, and are without prejudice to any permissions or approvals required under other applicable laws.
REFERENCES:
Reserve Bank of India. (2026). Reporting under Foreign Exchange Management Act, 1999 – Returns pertaining to External Commercial Borrowing (ECB). RBI/2025-26/253 A.P. (DIR Series) Circular No. 25. https://www.rbi.org.in/