RBI cuts forex derivative threshold to $5 million, bars rebooking of cancelled rupee contracts
Synopsis
Key Takeaways
The Reserve Bank of India (RBI) on Saturday, 10 October 2026, announced sweeping regulatory curbs on rupee-linked foreign exchange derivatives, slashing the unhedged transaction threshold from $100 million to $5 million and introducing a mandatory 20 per cent Foreign Exchange Risk Reserve (FERR) to clamp down on currency speculation and preserve market order.
Key Regulatory Changes
Under the new directions, authorised dealers are barred from permitting users to rebook any foreign exchange derivative contract involving the rupee — whether deliverable or non-deliverable — if that contract was cancelled with any authorised dealer after the issuance of the new directions. Rollover of contracts on maturity, however, will continue to be permitted.
The RBI has also sharply reduced the threshold for undertaking foreign exchange derivative transactions without establishing underlying exposure — from $100 million equivalent to $5 million equivalent — applying uniformly across all authorised dealers. The same threshold cut applies to positions in exchange-traded currency derivatives involving the rupee without underlying exposure, now capped at $5 million across all recognised stock exchanges.
The New Foreign Exchange Risk Reserve
For all rupee foreign exchange derivative contracts with a notional value exceeding $2 million equivalent undertaken to hedge current account exposures — where users purchase foreign currency against the rupee — authorised dealers must maintain with the RBI an FERR in cash equal to 20 per cent of the rupee equivalent of the notional amount. This reserve must be maintained daily until the contract is terminated.
Dealers are also required to report FERR details daily through the Centralised Information Management System. Any attempt by users to circumvent the requirement through multiple transactions will be treated as a direct violation, the central bank warned.
Undertaking and Compliance Requirements
Authorised dealers must now obtain and retain an undertaking from users entering into rupee foreign exchange derivative contracts to hedge contracted exposures, confirming that the same underlying has not been hedged with any other authorised dealer. This measure targets double-hedging — a practice that has reportedly been used to obscure the true scale of speculative positions.
When the Rules Take Effect
The RBI clarified that directions under Circular 25 come into force with immediate effect, while FERR directions under Circular 26 apply to contracts undertaken after the date of issuance. According to the central bank, the measures are designed to strengthen market discipline, ensure appropriate risk management, and maintain an orderly and transparent market environment.
Why This Move Matters
The tightening comes amid persistent concerns over speculative activity in the rupee derivatives market. By reducing the threshold twenty-fold — from $100 million to $5 million — the RBI has effectively narrowed the universe of entities that can take unhedged currency positions, bringing smaller but potentially disruptive players under tighter oversight. The FERR, functioning as a cash buffer, also raises the cost of large speculative bets, a mechanism broadly comparable to margin requirements used in equity derivatives. The rupee has faced intermittent pressure from global dollar strength and capital outflow cycles, making orderly hedging a macroprudential priority for the central bank.