Currency derivatives: SEBI aligns the no-underlying limit with RBI at USD 5 million across exchanges

Authority SEBIDate 5 Nov 2026Type CircularSubject Capital Markets

TaxByKK · Compliance News · taxbykk.com5 Nov 2026

In short

SEBI has revised the limit up to which domestic clients and Foreign Portfolio Investors may hold INR currency derivative positions on stock exchanges without showing an underlying exposure. The limit is now a single USD 5 million equivalent of notional value across all INR currency pairs and all exchanges, in line with RBI's circular of 10 October 2026.

Authority
SEBI, Market Regulation Department
Circular
HO/(561)2026-MRD-POD2/I/25177/2026 dated 5 November 2026
Type
Circular
Modifies
Clause 5.3.3 of the Master Circular for Stock Exchanges and Clearing Corporations dated 30 December 2024
Linked RBI circular
A.P. (DIR Series) Circular No. 25 dated 10 October 2026 on Risk Management and Inter-Bank Dealings (enclosed)
Addressed to
Stock exchanges, clearing corporations, depositories, DDPs, custodians and FPIs

What changed

ItemBeforeNow
Limit without underlying exposureEarlier limits in clause 5.3.3Single limit of USD 5 million equivalent notional value outstanding, across all INR currency pairs and all recognised exchanges
FPI short positions—Must not exceed USD 5 million across all FCY-INR contracts on all exchanges
FPI long positions above USD 5 million—Need an underlying exposure in Indian debt or equity securities, including equity or debt mutual fund units
Domestic clients above USD 5 million—Allowed subject to RBI's Master Direction of 5 July 2016 and RBI circular No. 25 of 10 October 2026

RBI's circular, enclosed with SEBI's, also prescribes added requirements on cancelling and rebooking foreign exchange derivative contracts and on documentation for hedging contracted exposures; the SEBI circular refers readers to it for compliance and does not summarise it. SEBI's circular does not state a separate effective date. Exchanges and clearing corporations must set up systems, amend bye-laws and rules, tell brokers and clearing members, and report implementation status to SEBI.

Who it applies to

  • Domestic clients and FPIs trading INR currency derivatives on exchanges
  • Stock brokers and clearing members
  • Stock exchanges, clearing corporations, custodians and DDPs
  • CAs and lawyers advising on treasury and FEMA matters

What to do

  1. Track notional INR currency derivative positions against the USD 5 million combined limit across all exchanges.
  2. For FPIs, keep short positions within USD 5 million and hold an underlying Indian debt or equity exposure for long positions above that.
  3. For domestic clients above USD 5 million, review the RBI circular of 10 October 2026 on documentation and cancellation and rebooking.

Reference

SEBI circular HO/(561)2026-MRD-POD2/I/25177/2026, 5 November 2026, Revision of limits relating to requirement of underlying exposure for currency derivatives contracts; issued under section 11(1) of the SEBI Act, 1992.

SEBICurrency derivativesFPIRBIFEMA
Read the official PDF: SEBI circular

Written by TaxByKK from the official notification. Check the official text before you act on it.

Frequently asked questions

What is the new limit without underlying exposure?

USD 5 million equivalent of notional value outstanding, put together across all INR currency pairs and all recognised stock exchanges.

Does it apply to FPIs?

Yes. FPIs must keep short positions within USD 5 million, and need an underlying Indian debt or equity exposure for long positions above it.

From when does it apply?

The circular does not state an effective date.