The Reserve Bank of India, through A.P. (DIR Series) Circular No. 25 dated 30 March 2026, revised reporting requirements for External Commercial Borrowing (ECB) under the Foreign Exchange Management Act, 1999. The circular clarifies that Form ECB 1 and Revised Form ECB 1 will be treated as returns that do not capture financial flows, affecting computation of Late Submission Fees (LSF). It further provides that each delayed submission of Form ECB 2 under a Loan Registration Number will be treated as a separate instance for LSF calculation. Authorised Dealer Category I banks are required to submit complete returns to the RBI within seven days of receipt from borrowers. Payment of LSF must be made through NEFT or RTGS after RBI acknowledgment, and banks must monitor compliance by borrowers. Effective from 1 April 2026, the changes aim to streamline reporting, ensure timely submission, and strengthen compliance oversight under FEMA.
Reserve Bank of India
RBI/2025-26/253
A.P. (DIR Series) Circular No. 25 | Dated: March 30, 2026
All Authorised Dealer Category I Banks,
Madam / Sir,
Reporting under Foreign Exchange Management Act, 1999 – Returns pertaining to External Commercial Borrowing (ECB)
Attention of Authorised Dealer Category I banks is invited to A.P. (DIR Series) Circular No. 16 dated September 30, 2022 and Part V and XIII of Master Direction – Reporting under Foreign Exchange Management Act, 1999.
2. On a review, the following changes are being made to the extant directions with reference to the returns pertaining to External Commercial Borrowing (ECB):
(i) Form ECB 1 and Revised Form ECB 1 (known as Form ECB and Revised Form ECB respectively prior to notification of Foreign Exchange Management (Borrowing and Lending) (First Amendment) Regulations, 2026) shall be treated as returns which do not capture flows. Late Submission Fee for delayed submission of these forms shall be computed accordingly;
(ii) LSF amount is per return. Therefore, each delayed submission of Form ECB 2 return submitted under a Loan Registration Number (LRN) shall be treated as a separate instance for computation of the fixed component of LSF;
(iii) The designated AD Category I bank shall submit the return (complete in all aspects) received from the eligible borrower, along with due certification, to the Reserve Bank within seven calendar days from the date of its receipt;
(iv) The LSF, wherever applicable, shall be payable at the Regional Office concerned of the Reserve Bank by way of NEFT or RTGS, post receipt of an e-mail from the Reserve Bank acknowledging receipt of the return. Detailed instructions in this regard will be contained in the said acknowledgment e-mail; and
(v) In case of delayed submission of returns, the designated AD Category I bank shall monitor payment of applicable LSF by their customers/ constituents.
3. These directions shall come into effect from April 01, 2026.
4. Authorised Dealer banks may bring the contents of the circular to the notice of their customers/ constituents concerned.
5. The directions contained in this circular have been issued under sections 10(4), 11(1) and 11(2) of the Foreign Exchange Management Act, 1999 (42 of 1999) and are without prejudice to permissions / approvals, if any, required under any other law.
Yours faithfully,
(Dr. Aditya Gaiha)
Chief General Manager-in-Charge
