Forex desk
What an AD Category-I Bank Reports to RBI: The 37 Forex and Trade Returns
The forex desk's own filing list (FETERS, BAL, NRD-CSR, LRS, ECB and the rest) pulled from RBI's returns inventory and split by frequency. Plus why EDPMS and XOS are not on it.
By Aaryan Kakani · · 17 min read
What Does an AD Category-I Bank Actually File With RBI?
RBI publishes a single authoritative inventory of everything it collects from regulated entities: the List of All Returns . It carries 243 returns . Filter the entity column (the column that names who has to file) on Authorised Dealer banks, and exactly 37 come back. Those 37 are the whole of an AD Category-I bank's forex and trade reporting universe as RBI itself documents it.
The 37 split across four departments: the Foreign Exchange Department (FED) owns 21, the Financial Markets Regulation Department (FMRD) owns 10, the Department of Statistics and Information Management (DSIM) owns 4, and the Department of Economic and Policy Research (DEPR) owns 2. Set against the departmental totals on the same list (FED 42, FMRD 15, DSIM 17, DEPR 4) that means an AD bank carries half of everything FED collects from anyone and two-thirds of FMRD's entire return set .
Four columns on that list decide everything downstream. The entity column decides who the reporting person is. The frequency column carries the deadline. The department column tells you which RBI desk owns the data and will raise the query. The circulars column tells you which instrument mandates the return. And whether a public format exists at all. Read in that order, they settle applicability without guesswork.
Contrast this with the exporter-facing view of the same relationship. An exporter files nothing on this list. Its shipping bills, its realisation evidence and its documentary submissions all enter RBI's data through the AD. The AD's obligation is separate, continuous, and owed to RBI rather than to the customer. Which is why a bank keeps chasing paperwork long after the exporter considers the transaction closed.
All 37 AD-filer returns, in RBI's own S.No order
| S.No | Return name | Dept | Frequency (verbatim) | Filer entity (verbatim) | Governing circular or Master Direction |
|---|---|---|---|---|---|
Applicability is decided by four columns on RBI's own list, read in order: entity tells you whether the bank files or merely transmits, department tells you which instrument governs, frequency carries the real deadline in prose, and circulars tells you whether a public format exists at all. Anything not on the list is not a return. Which is why EDPMS, IDPMS, XOS and BEF have no due date, and why a clean EDPMS dashboard discharges none of the 37. </> } />
Why Are EDPMS, IDPMS, XOS and BEF Missing From RBI's 243-Return List?
Search all 243 entries by return name, by description and by circular text. EDPMS, IDPMS, XOS and BEF return zero hits . Not one of the four appears anywhere on RBI's List of All Returns.
This is not an omission by RBI. It is a category distinction that the list makes precisely. A return on this list is a periodic data submission with a prescribed format, a frequency, an owning department and a circular or Master Direction that mandates it. 236 of the 243 entries carry a real citation in the circulars column. EDPMS and IDPMS have none of those attributes, because they are not submissions at all. They are transaction-matching databases that AD banks operate continuously, fed by Customs shipping bill and bill of entry data on one side and by the bank's own remittance postings on the other. There is no fortnight-end or quarter-end cut-off because there is no reporting period.
XOS and BEF are a step removed again. They are periodic statements of what those systems left unmatched (outstanding export bills in the case of XOS, unreconciled advance import remittances in the case of BEF) and they are raised under the Export of Goods and Services and Import of Goods and Services Master Directions rather than under the List of All Returns regime. Real obligations, different instrument, different index.
Why do filers get this wrong so consistently? Partly because RBI's own reporting FAQ index invites the confusion. The ReportingFAQ page publishes no inline question-and-answer text at all. It is a download index of six ZIP bundles. One of them, IDPMS_EDPMS_24082022.zip , pairs IDPMS and EDPMS in a single archive and sits directly alongside FETERS_24082022.zip and the FIRMS FAQ bundle. Four names in one folder reads as one regime. It is not.
| System | On RBI's 243-return list? | What it actually is | What triggers activity | Where the obligation is written | What the AD bank is accountable for |
|---|---|---|---|---|---|
| EDPMS | No. Zero hits across all 243 entries | Export data processing and monitoring system: a transaction-matching database the bank operates continuously | A Customs shipping bill arriving, or an inward remittance being posted against it | Master Direction on Export of Goods and Services | Keeping entries matched and closed. Not meeting a due date, because there is none |
| IDPMS | No. Zero hits | Import data processing and monitoring system: the import side of the same matching architecture | A bill of entry arriving, or an outward remittance being posted against it | Master Direction on Import of Goods and Services | Evidencing import against every outward remittance it processed |
| XOS | No. Zero hits | A periodic statement of export bills the matching system left outstanding | A half-year closing with export bills still unrealised | Master Direction on Export of Goods and Services | Filing the statement. The obligation survived EDPMS and was not replaced by it |
| BEF | No. Zero hits | A periodic statement of advance import remittances with no matching evidence of import | An advance remittance ageing without a bill of entry against it | Master Direction on Import of Goods and Services | Chasing import evidence from the customer and reporting what stays unreconciled |
How Does the Fortnightly FETERS R-Return Work, and What Ships Alongside It?
Read the inventory entry as RBI writes it. FETERS (R-return) , described as "Foreign exchange transactions of banks in India", frequency Fortnightly , department DSIM , filer entity "AD Category - I Banks and IFSC Banking Units (IBUs)", governed by A.P. (DIR Series) Circular No. 50 dated February 11, 2016 and A.P. (DIR Series) Circular No. 25, dated March 20, 2019. This is the statistical backbone of India's balance of payments compilation, and it is the return most people mean when they say "the R-return".
Three further DSIM returns travel with FETERS and are routinely treated as parts of it. They are not. Each is separately listed and separately mandated.
- BAL statement. Fortnightly, DSIM, "Foreign currency balances held abroad and balances held in Non-Resident accounts of overseas branches and correspondents", filed by AD Category - I Banks and IBUs under A .P. (DIR Series) Circular No. 3, dated August 10, 2017.
- NRD-CSR. Monthly, DSIM, the non-resident deposits comprehensive single return on NR/FCNR deposits and their transactions in a month. Note the wider filer scope: "All Banks Authorised to deal in Foreign Exchange", under the Master Direction. Reporting under Foreign Exchange Management Act, 1999.
- FETERS. Cards Return. Monthly, DSIM, international credit card, debit card and UPI transactions with merchant category code classification, under A.P. (DIR Series) Circular No.13, dated March 25, 2021.
There is a second BAL-form obligation that does not belong to DSIM at all. FMRD separately lists Holding of Foreign Currencies , described as a "Statement in form BAL giving details of holding of all foreign currencies by AD Bank", Fortnightly, under the Master Direction - Risk Management and Inter-Bank Dealings. Same form name, different department, different instrument, separate line on the list.
| Return name | Frequency | Dept | Filer entity | Mandating circular | What it captures |
|---|---|---|---|---|---|
Which Forex Returns Does an AD Bank File Every Single Day?
Across all 243 returns RBI collects from every regulated entity in the country, only five carry a Daily frequency. Four of the five are the AD bank's.
- LEC-FII and LEC-NRI (FED). The statement of purchases and sales of equity instruments made by FPIs and NRIs on a recognised stock exchange in India or on an international exchange, under the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019.
- Liberalised Remittance Scheme (FED). "Liberalised Remittance Scheme of USD 2,50,000 for resident individuals". The circulars column records the instrument as the LRS notification discontinuing the monthly return, which is exactly why the surviving obligation is daily.
- Foreign Exchange Turnover (FTD) (FMRD). Client and interbank turnover in spot, swaps and forwards, including cancellations.
- Gaps, Position, and Cash Balances (GPB) (FMRD). Gaps of foreign currency, net open exchange positions and cash balances.
The fifth daily return on the list is Currency Chest Transactions, owned by the Department of Currency Management. It is a physical cash obligation and has nothing to do with forex. Worth knowing only so nobody counts it into the treasury workload.
A structural point worth carrying: FTD and GPB are mandated by the same instrument (Master Direction - Risk Management and Inter-Bank Dealings, RBI/FMRD/2016-17/31, FMRD Master Direction No. 1/2016-17, July 5, 2016) which alone accounts for seven of the 37 AD returns. One Master Direction, seven filing obligations, four different frequencies.
| Return name | Dept | Filer entity (verbatim) | What is reported | Mandating instrument | Published format size |
|---|---|---|---|---|---|
Which AD Bank Returns Are Trade-Specific Rather Than Treasury?
Most of the 37 are treasury returns. Turnover, positions, balances, deposits, card flows. A smaller set is triggered directly by what an exporter or importer does. For an exporter reading this page, these are the returns in which your own transaction appears.
- Statement on default in MTT. Half-yearly, FED, defaults in Merchanting Trade Transactions, under A.P. (DIR Series) Circular No.95 dated January 17, 2014 read with A.P. (DIR Series) Circular No.115 dated March 28, 2014 on revised MTT guidelines.
- Reporting of Long term Advance. Yearly, FED, long term export advances of USD 100 million and more with a progress report on utilisation, under A.P. (DIR Series) Circular No.132 dated May 21, 2014 on Export of Goods - Long Term Export Advances.
- Issuance of guarantee for Trade Credit. Quarterly, FED, under A. P. (DIR Series) Circular No. 10 dated December 22, 2023.
- Form TC. Monthly, DEPR, "short term credit extended for imports and payments thereof", filer "ADs", under RBI/2004/154 A.P.(DIR Series) Circular No. 87 dated April 17, 2004. This is the oldest circular governing any of the 37.
- Import of gold by EOUs, units in SEZ/EPZ and nominated agencies (Monthly/ Half Yearly, FED, under the Master Direction) Reporting under Foreign Exchange Management Act, 1999.
- The two diamond-trade returns. Extension of time on clean credit for import of rough, cut and polished diamonds (Half-yearly, format not prescribed, AP (DIR Series) Circular No.57 dated March 31, 2016), and advance remittances for import of rough diamonds without a bank guarantee or standby letter of credit at or above USD 5,000,000 (Half-yearly, as per format annexed to the circular, A.P. (DIR Series) Circular No.116 dated April 01, 2014).
- Suspicious Transactions undertaken by Non-Resident Importer/Exporter. Quarterly, FMRD, trade-adjacent rather than trade specific: doubtful transactions involving frequent cancellation of hedge transactions and / or the underlying trade transactions.
| Return name | Frequency | Dept | What triggers a line item | Governing circular | Exporter-side event that causes it |
|---|---|---|---|---|---|
A Mumbai trading company runs a merchanting trade transaction through its AD Category-I bank: goods bought from a Vietnamese supplier, shipped directly to a Nigerian buyer, never entering India. The bank remits the import leg on schedule. The export leg receivable falls due and the Nigerian buyer does not pay. The relationship manager treats it as a customer credit problem. The exporter, who has read the bank's own guidance on export realisation, assumes EDPMS will surface it. Both are wrong about where this lands. </> } result= >
| Step | What is done | What it settles |
|---|---|---|
| 1 | Classify the event. There is no shipping bill, because the goods never crossed an Indian port. | EDPMS is fed by Customs shipping bill data matched against inward remittance postings, so a merchanting default generates no EDPMS entry to age or close. Searching RBI's 243-return list for EDPMS confirms it is not a return at all, so there is no EDPMS deadline to work backwards from. |
| 2 | Find the return that does capture it. | RBI's list carries "Statement on default in MTT", described as "Statement on default in Merchanting Trade Transactions (MTT)", filed Half-yearly by AD Category - I Banks, department FED, under A.P. (DIR Series) Circular No.95 dated January 17, 2014 read with A.P. (DIR Series) Circular No.115 dated March 28, 2014. |
| 3 | Read the entity column. It reads "AD Category - I Banks", not "through the AD bank". | This is a principal filing: the bank is the reporting person, the exporter is the subject. The exporter cannot file it, cannot cure it by filing something else, and cannot make it go away by settling with the bank. |
| 4 | Read the frequency column verbatim: "Half-yearly". | The default enters the statement for the half-year in which it occurred. It does not wait for the customer's explanation or for a write-off decision. |
| 5 | Check for adjacent obligations triggered by the same facts. | A guarantee or standby instrument on this structure makes Form GRN Issue (and, on a call, Form GRN Invocation) due through the AD on a quarterly basis within 15 calendar days from the end of the respective quarter, under the Foreign Exchange Management (Guarantees) Regulations, 2026, as conduit filings. Trade credit against the import leg makes "Issuance of guarantee for Trade Credit" (Quarterly, FED, A. P. (DIR Series) Circular No. 10 dated December 22, 2023) and the DEPR monthly Form TC separately live. A hedge cancelled when the underlying failed is exactly the pattern the FMRD quarterly return "Suspicious Transactions undertaken by Non-Resident Importer/Exporter" is built to capture. |
| 6 | Retain proof. | RBI publishes no return-to-portal map, so the filing evidence is the system-generated acknowledgement plus the correspondence trail with the FED Regional Office having jurisdiction over the bank's registered office. |
When Does the Bank File, and When Does the Customer File Through the Bank?
This is the distinction that stops a bank double-filing or under-filing, and it is read straight off the entity column. The 37 split into two archetypes.
Twenty-nine are principal filings. The entity reads "AD Category - I Banks", "ADs" or "All Banks Authorised to deal in Foreign Exchange". The bank originates the data from its own books, and the failure mode is data quality.
Eight are conduit filings. The customer is the reporting person and the AD is the channel: Form ECB 1, Revised Form ECB 1 and Form ECB 2 under the Foreign Exchange Management (Borrowing and Lending) Regulations, 2018 read with the Master Direction. Reporting under FEMA, 1999; Form FC and Form APR under the Master Direction - Overseas Investment dated July 24, 2024; and Form GRN Issue, Form GRN Modification and Form GRN Invocation under the Foreign Exchange Management (Guarantees) Regulations, 2026.
| Form | Reporting person (verbatim) | Deadline (verbatim) | Governing regulation | What the AD must verify before transmitting | What breaks if the customer goes silent |
|---|---|---|---|---|---|
Which RBI Department Owns Each Return, and Where Is It Submitted?
Each of the four departments has a distinct character, and knowing which one owns a return tells a compliance officer who will call when a number looks wrong.
- FED (21 of the 37) owns the FEMA-permission returns: remittances, overseas direct investment, guarantees, trade credit, gold and diamond imports, the LO/BO/PO register, and the annual review note on the vostro accounts of Exchange Houses maintained under Rupee and Foreign Currency Drawing Arrangements.
- FMRD (10) owns the Master Direction - Risk Management and Inter-Bank Dealings cluster, plus the newer instruments: FX- Transactions- Retail platform under the FX-Retail rollout, and Report on transactions in gold derivatives in exchanges under FMRD.FMD.No.08/02.03.185/2024-25 dated December 27, 2024. The most recent instrument in the whole AD set.
- DSIM (4) owns statistics: FETERS (R-return), the BAL statement, NRD-CSR and the FETERS. Cards Return.
- DEPR (2) owns Form TC and Yen holdings of Government of India, the latter attributed on RBI's list to the Master Direction - External Commercial Borrowings, Trade Credit, Borrowing and Lending in Foreign Currency by ADs and Persons other than ADs.
Submission channels are where public documentation thins out sharply. RBI's Reporting Portals page (whose URL is itself misspelled on RBI's own site as ReportingPlaform.aspx with one "t", so any deep link has to reproduce the typo) lists exactly nine portals : BoP (bop.rbi.org.in), FLAIR (flair.rbi.org.in), SMS (sms.rbi.org.in), FED (fed.rbi.org.in), CISBI (cisbi.rbi.org.in), FIRMS (firms.rbi.org.in/firms), Data Collector (datacollector.rbi.org.in), CIMS DRM (sankalan.rbi.org.in) and CIMS Common Login (cims.rbi.org.in). Names and URLs only. No descriptions, no onboarding instructions, no helpdesk detail. The only migration sentence RBI publishes there reads: "Existing XBRL, DBIE and SAARC portal will be discontinued once complete CIMS project goes LIVE."
| Department | Returns in the AD-37 | Character of the obligation | Anchor instrument | Known submission channel |
|---|---|---|---|---|
| FED. Foreign Exchange Department | 21 | FEMA permissions and the evidence trail behind them: remittances, ODI, guarantees, trade credit, gold and diamond imports, vostro review | Master Direction. Reporting under Foreign Exchange Management Act, 1999, plus the A.P. (DIR Series) circulars cited per return | Not published per return; FED Regional Office having jurisdiction over the registered office is the standing correspondent |
| FMRD. Financial Markets Regulation Department | 10 | Market conduct and risk: turnover, positions, hedges, options, commodity and gold derivatives, retail FX platform distribution | Master Direction - Risk Management and Inter-Bank Dealings, RBI/FMRD/2016-17/31, July 5, 2016 (7 of the 10) | Not published by RBI at return level |
| DSIM. Statistics and Information Management | 4 | Statistical compilation feeding balance of payments and external sector data | A.P. (DIR Series) Circular No. 50 dated February 11, 2016 and the per-return circulars for BAL, NRD-CSR and Cards | Not published; validation rules sit behind CIMS DRM at sankalan.rbi.org.in |
| DEPR. Economic and Policy Research | 2 | Research inputs on short term import credit and international investment position | A.P.(DIR Series) Circular No. 87 dated April 17, 2004 for Form TC; the ECB and Trade Credit Master Direction for Yen holdings | Not published by RBI at return level |
AD Category-I Return Calendar and Pre-Submission Checklist
All 37 returns, grouped by cycle, with the deadline text exactly as RBI writes it. The verbatim column is the point of the table: it is what keeps an event-triggered obligation from being flattened into a calendar bucket.
| Cycle | Return name | Dept | Filer archetype | Deadline text, verbatim from RBI's list |
|---|---|---|---|---|
Pre-submission checklist
- Confirm the item is a return on RBI's List of All Returns and not the output of a matching system. EDPMS, IDPMS, XOS and BEF are not on it
- Read the entity column to decide principal versus conduit before assigning the work to a team
- Take the frequency string verbatim rather than normalising it into a calendar bucket
- Verify the governing circular or Master Direction is the current version, not an internal template built from a superseded one
- Retain the system-generated acknowledgement as filing proof at the return level, not a portal screenshot
- File the nil return where the cycle demands one. Form ECB 2 being the standing example
- Escalate to the FED Regional Office having jurisdiction over the registered office where the channel or applicability is undocumented
Disclosure: where each fact on this page comes from
- Read directly from RBI's published list. The 243 total, the departmental split, the 37 AD-filer returns, and every return name, description, frequency, department, filer entity and format size quoted above. Source: List of All Returns .
- Read from RBI circulars and Master Directions. The substance of each obligation, cited inline by circular number and date as recorded in the list's circulars column.
- Not available publicly, because it sits behind CIMS login. Return-wise field mappings, numeric field codes, XBRL tags and validation rules. RBI's Data Definitions page carries prose only, and ValidationRules points to sankalan.rbi.org.in . Also unpublished: any mapping from the 37 returns to the nine portals listed on RBI's Reporting Portals page .
Frequently asked questions
Is EDPMS a return that an AD bank has to file with RBI?
No. EDPMS does not appear anywhere in RBI's List of All Returns, which carries 243 returns in total. EDPMS is a transaction-matching system that AD banks operate continuously, fed by Customs shipping bill data and the bank's own inward remittance postings. A return, on RBI's list, has an owning department, a frequency, a filer entity and a mandating circular. EDPMS has none of these because it has no reporting period. There is no EDPMS due date to miss, and a clean EDPMS dashboard discharges none of the 37 forex and trade returns an AD Category-I bank actually owes RBI.
How many returns does an AD Category-I bank actually file, and which RBI departments own them?
Exactly 37 of the 243 returns on RBI's List of All Returns name an Authorised Dealer bank in the filer column. They split across four departments: the Foreign Exchange Department (FED) owns 21, the Financial Markets Regulation Department (FMRD) owns 10, the Department of Statistics and Information Management (DSIM) owns 4, and the Department of Economic and Policy Research (DEPR) owns 2. That is half of everything FED collects from anyone (42 returns) and two-thirds of FMRD's entire set (15 returns). A bank's prudential obligations to DoS (105 returns), FIDD (18), DoR (17) and DPSS (8) sit outside this forex and trade set.
Does an IFSC Banking Unit have to file the FETERS R-return, or is it outside the FETERS scope?
An IFSC Banking Unit is inside the FETERS obligation. RBI's List of All Returns records the filer entity for FETERS (R-return) as "AD Category - I Banks and IFSC Banking Units (IBUs)", fortnightly, owned by DSIM, under A.P. (DIR Series) Circular No. 50 dated February 11, 2016 and A.P. (DIR Series) Circular No. 25, dated March 20, 2019. The fortnightly BAL statement carries the same "AD Category - I Banks and IBUs" filer scope. Banks that treat the IBU as offshore for reporting purposes are reading the entity column wrong.
Who is the reporting person on Form ECB 2 and Form GRN Issue. The bank or the customer?
The customer is the reporting person on both; the AD bank is the channel. RBI's entity column for Form ECB 2 reads "Borrower through the designated AD Category-I Bank", due within 7 calendar days from the end of the month in which the proceeds were received or debt servicing was undertaken. For Form GRN Issue it reads "The person having the obligation to report the guarantee through AD bank", due on a quarterly basis within 15 calendar days from the end of the respective quarter under the Foreign Exchange Management (Guarantees) Regulations, 2026. On these conduit filings the bank's failure mode is not late data but unverified data: the customer's silence becomes the bank's non-submission.
Did EDPMS replace XOS, and does the AD bank still have to file the half-yearly XOS statement?
EDPMS did not replace XOS. EDPMS changed how the outstanding export bill data is assembled, but the periodic XOS statement obligation on the AD bank survives. Neither XOS nor BEF appears on RBI's 243-return List of All Returns, because both are periodic statements of what the matching systems left unmatched (outstanding export bills in the case of XOS, unreconciled advance import remittances in the case of BEF) and both are raised under the Export of Goods and Services and Import of Goods and Services Master Directions rather than under the List of All Returns regime.
Update history
- First published.