FX Code
The FX Global Code: what your bank signed and what it owes you
A voluntary code, honestly framed. The principle areas, the Statement of Commitment, and the specific principles on pricing transparency and mark-up disclosure you can point to.
By Aaryan Kakani · · 8 min read
Is the FX Global Code a law your bank must follow?
No. That is the honest answer, and it is worth stating before anything else on this page. The Code says so itself: it "does not impose legal or regulatory obligations on Market Participants, nor does it substitute for regulation." It is a voluntary set of good-practice principles for the wholesale foreign exchange market, maintained by the Global Foreign Exchange Committee (GFXC).
The Code was first published in May 2017 and revised in July 2021. The current edition is the third, dated December 2024 and published in January 2025 following the GFXC Three-Year Review held on 5. 6 December 2024.
For an Indian exporter, that means one plain thing: a bank signing the Code gives you a stated commitment to conduct standards, not an enforceable right. There is no audit behind it, no regulator policing it, and no penalty clause you can invoke.
So why does it still matter? Because a bank that has publicly signed has put its own name against specific, numbered conduct standards on pricing, mark-up and order handling (and you can quote those numbers back to your FX desk. "Your rate was bad" is a grievance. "Principle 14 of the Code your bank has signed commits you to a fair and reasonable mark-up with transparency on my final price) please send me your mark-up policy" is a question that has to be answered.
| Layer | What it is | Binding on your bank? | What you can do with it |
|---|---|---|---|
| FEMA | Statute governing foreign exchange transactions in India | Yes. Law | Compliance obligations on both you and the bank. See the FEMA compliance guide |
| RBI directions | Master Directions and circulars issued to AD banks | Yes. Regulatory | Escalate non-compliance to the bank, then to the regulator's grievance channel |
| FEDAI Rules | Clause printed on every FX contract note you sign | Yes. Contractual | Enforceable asks on charges and card rates. See the FEDAI rules guide |
| FX Global Code | Voluntary conduct principles, self-certified by signature | No. Voluntary | Cite principle numbers in writing; a signatory cannot deny the standards apply to it |
The rest of this page covers what the Code actually contains, how to verify whether your bank signed it, where India stands, and the exact principles worth citing when you talk to an FX desk.
What do the 55 principles actually cover?
The Code contains 55 principles grouped into six areas. Two of those six (Execution and Information Sharing) are where a bank customer's real interests sit. The others are largely about how the bank runs itself.
| Area | Principles | What it governs | Why an exporter should care |
|---|---|---|---|
| Ethics | 3 | Standards of honesty, fairness and professionalism inside the firm | Background culture. Rarely cited directly by a customer |
| Governance | 4 | Board and senior-management oversight of the FX business | Tells you someone senior owns the desk's conduct |
| Execution Customer-facing | 11 | Dealing capacity, order handling, pre-hedging, mark-up, last look | This is your price. Principles 8, 9, 10, 11, 14 and 17 all live here |
| Information Sharing Customer-facing | 5 | What the bank may and may not do with knowledge of your orders | Your pending conversions are Confidential Information (P19. 20) |
| Risk Management & Compliance | 18 | Risk frameworks, controls and compliance around FX activity | Mostly internal, but includes settlement-risk practice that affects you |
| Confirmation & Settlement | 14 | Post-trade confirmation, settlement and reconciliation | Back-office, but drives how fast you get a clean contract note |
| Total | 55 | Six areas, one voluntary code | 16 of the 55 sit in the two customer-facing areas |
Ethics and Governance are about the firm's internal culture and oversight. Who sets the tone and who is accountable for the desk. Execution is where pricing, mark-up, order handling and last look live, and it is the area that touches an exporter most directly. Information Sharing governs what the bank may and may not do with the knowledge that you have a conversion coming. Risk Management and Compliance and Confirmation and Settlement are largely back-office, though the December 2024 edition strengthened the FX settlement-risk guidance in that part of the Code.
The December 2024 edition also brought greater transparency expectations on certain FX transaction types and on the use of client-generated data on e-trading platforms, plus enhanced Disclosure Cover Sheets for liquidity providers and platforms.
What does it mean when a bank signs the Statement of Commitment?
The Statement of Commitment is Annex 3 of the Code. A one-page voluntary form. Per the Code's Explanatory Note, signing represents three things: an independent determination to support the Code; a commitment to conduct FX activities consistently with its principles; and a self-assessment that the firm has taken proportionate steps to align its practices.
| A signed Statement of Commitment IS | A signed Statement of Commitment IS NOT |
|---|---|
| A public, named declaration that the firm supports the Code | A contract between the bank and you |
| A commitment to conduct FX activity consistently with the 55 principles | Externally audited. It is self-certified |
| A self-assessment that proportionate steps to align have been taken | Backed by an enforcement body or penalty regime |
| Published on a public register with a date you can cite | Subject to expiry-driven external re-examination |
Read practically, a signed Statement is the bank publicly saying: our FX desk conducts itself to these 55 principles. That is not a contract you can sue on. It is a standard you can hold up in a conversation, or in a written complaint to the bank. And a desk that has signed cannot turn around and say the principles don't apply to it.
How do you check whether your bank has signed the Code?
Statements of Commitment are published on public registers hosted by central banks, FX committees and industry bodies. Verified examples include the BIS Central Bank Register, AFMA, CLS, Assiom Forex, and India's Indian Foreign Exchange Committee (IFXC).
The GFXC maintains a Global Index of Public Registers at globalfxc.org/global_index.htm that consolidates them. As of December 2024 the Index reflected over 1,300 Statements of Commitment. GFXC's own figure, which it notes may involve double counting where a firm appears on more than one register.
| Step | What to do | Watch out for |
|---|---|---|
| 1 | Open the GFXC Global Index of Public Registers | The Index links to registers; it is not itself a single searchable list of firms |
| 2 | Pick the relevant register. For India, the IFXC; for a global bank, its home-market committee register | A firm can appear on several registers, which is why the 1,300+ figure may double count |
| 3 | Search the bank's legal name | Search the group entity, not your branch. Branches are not listed separately |
| 4 | Note the register name and the date of the Statement | The date is what you cite; save a screenshot or the URL |
| 5 | If the bank is not listed, ask the relationship manager directly | Absence is not misconduct (adoption is voluntary) but it is a fair question |
What you do with the result matters more than the search. If your bank appears, save the register entry. It is the citation behind every question in the checklist section below. If it does not appear, that itself is worth putting to the relationship manager: has the bank signed, and if not, which conduct standards does its FX desk work to instead?
Where does India stand on the FX Global Code?
RBI has itself signed the Statement of Commitment, and renewed it on 24 September 2025 (RBI Press Release 2025-2026/1156). The central bank has put its own name to the Code for its own FX operations.
India's public register is the Indian Foreign Exchange Committee (IFXC), formed with RBI facilitation and listed as a GFXC Participating Public Register.
| Question | Verified position | Source |
|---|---|---|
| Has RBI signed the Code? | Yes. Statement of Commitment renewed on 24 September 2025 | RBI Press Release 2025-2026/1156 |
| Which register covers India? | The Indian Foreign Exchange Committee (IFXC), formed with RBI facilitation | GFXC list of Participating Public Registers |
| Must Indian AD banks sign? | No RBI circular mandating adherence by AD banks was found in the research for this page. Adoption appears voluntary | Not established; do not assume a mandate |
| Has your own bank signed? | An empirical question. Check the register, do not infer it from RBI's signature | GFXC Global Index of Public Registers |
There is a useful asymmetry here for customers. The regulator that supervises your AD bank has publicly committed to these standards for its own FX operations. That makes "do you follow the Code that RBI has itself signed?" a fair and pointed question to put to any Indian FX desk. Without claiming any obligation that does not exist.
Which principles cover the price and mark-up your bank quotes you?
Four principles carry almost all of the pricing weight for a bank customer. Learn the numbers. Citing them is what separates a question from a complaint.
| Principle | What it says | When you'd invoke it | What to ask your desk |
|---|---|---|---|
| Principle 8 | Be clear about the capacity in which you deal. Principal or agent | You assumed the bank was getting you the market rate, and it was trading against you | "When you quote me a rate, are you acting as principal or as agent?" |
| Principle 11 | Pre-hedging is permitted only when acting as principal, and must be fair and transparent | The rate moved against you between your phone call and the deal being struck | "Do you pre-hedge client orders, and how do you ensure I am not disadvantaged?" |
| Principle 14 Your main lever | Mark-up should be fair and reasonable, with enough transparency for the client to understand its final price | An unexplained 60-paise gap between the rate on your credit advice and the interbank rate | "What is the mark-up on this transaction over the mid-market rate, and how is it determined?" |
| Principle 17 | If last look is used, disclose how it works and why trades are rejected; do not misuse trade-request information | The bank's online FX platform rejects your click and re-quotes worse | "Does your platform apply last look, and what is your rejection policy?" |
Principle 8 matters more than it looks. Most bank FX desks deal with you as principal (trading against you at their own price rather than executing on your behalf in the market) which is precisely why a spread exists at all. Once you know the desk is a principal, you stop asking why there is a margin and start asking how large it is and how it is set.
Principle 11 covers pre-hedging: permitted only when the bank acts as principal, and required to be done fairly and transparently, without trading ahead of your order in a way that disadvantages you. Principle 14 is the strongest hook an exporter has, because it addresses the thing you actually feel. The mark-up. Principle 17 matters if you deal on the bank's electronic platform rather than by phone.
How should your bank handle your orders and your information?
The second cluster covers what happens to an instruction you leave with the desk, and to the knowledge that you left it. Exporters leave more standing instructions than they realise. "convert my inward remittance when USD/INR touches X" is an order, and the Code has something to say about how it is handled.
| Principle | What it says | Exporter situation it maps to |
|---|---|---|
| Principle 9 | Client orders must be handled fairly and with transparency | A rate-triggered conversion order left with the desk on your inward remittance |
| Principle 10 | Fairness obligations specific to order type. Stop-loss, limit and fixing orders each carry disclosure expectations | A limit order to convert EEFC balances, or a fixing-linked conversion for a large shipment payment |
| Principle 19 | Client orders and trading intentions are Confidential Information, with access limited inside the firm | Who at the bank knows you have USD 2 million to sell this week |
| Principle 20 | Confidential Information must not be disclosed beyond a valid need to know | The risk that knowledge of your pending conversion moves the price you eventually get |
On Principle 10 specifically: the bank should tell you its handling policy per order type, not one vague blanket line in the terms. A limit order and a fixing order are handled differently, and you are entitled to know how each is treated before you leave the instruction.
The FX desk question checklist
This is the payoff. Each question below is anchored to a principle number or a register fact, so it cannot be brushed off as a complaint about a rate.
| # | Question to put to the desk or RM | Anchor |
|---|---|---|
| 1 | "Has the bank signed the FX Global Code Statement of Commitment, and on which public register is it published?" | Verify yourself first via the GFXC Global Index |
| 2 | "When you quote me a rate, are you acting as principal or agent?" | Principle 8 |
| 3 | "What is the mark-up on this transaction over the interbank/mid-market rate, and how is it determined? Principle 14 commits you to a fair and reasonable mark-up and transparency on my final price." | Principle 14 |
| 4 | "How do you handle my rate-triggered conversion orders. What is your handling policy for limit and stop orders?" | Principles 9 and 10 |
| 5 | "Do you pre-hedge client orders, and how do you ensure I'm not disadvantaged?" | Principle 11 |
| 6 | "Does your platform apply last look, and what is your rejection policy?" | Principle 17 |
| 7 | "Who inside the bank can see my pending orders and conversion intentions?" | Principles 19 and 20 |
How to send it
- Put the questions in writing (an email to the relationship manager, not a phone call) so the answers are on record.
- Verify the Statement of Commitment on the register before you send, so question 1 is a confirmation rather than an opening.
- Pair the Code questions with the contractually binding asks from FEDAI General Guidelines (display of card rates and the card-rate threshold) covered in the FEDAI rules guide .
- Attach the specific transaction: deal reference, date, amount, rate received, and the reference rate you compared against.
- Ask for the mark-up policy as a document, not as a sentence in a reply email. A policy applies to every future conversion.
An apparel exporter in Tirupur receives USD 100,000 against a shipment. The bank converts it at Rs 83.05 and credits Rs 83,05,000. Checking that day's interbank USD-INR level, the exporter finds the market was around Rs 83.60 at the time of credit. A 55-paise gap, with no forward contract and no rate ever discussed on the phone. </> } result= >
| Step | Action | Working / output |
|---|---|---|
| 1. Quantify | Compute the retained exchange margin | 100,000 × (83.60 − 83.05) = Rs 55,000, i.e. About 0.66% of the transaction |
| 2. Classify | Decide what kind of cost this is | Not a fee on any charge schedule. It is FX mark-up, the exact subject of Principle 14, which a signatory bank has committed keeps mark-up fair and reasonable with enough transparency for the client to understand the final price |
| 3. Verify the commitment | Search the bank on the GFXC Global Index of public registers | Statement of Commitment located; register name and date noted for citation |
| 4. Write, not call | Email the relationship manager with the full record | Deal reference, credited rate 83.05, interbank level ~83.60, computed Rs 55,000 margin, the published Statement of Commitment, and two asks. (a) the mark-up policy for inward remittances in writing, citing Principle 14, and (b) confirmation of the card rate displayed that day and the bank's card-rate threshold, which FEDAI's General Guidelines require it to declare |
| 5. Negotiate forward | Convert the dispute into a standing arrangement | Rates quoted at a stated margin over interbank for future remittances, with each conversion confirmed at deal time |
Sources & citations
- [GFXC. FX Global Code (December 2024 edition)](https://www.globalfxc.org/fx_global_code.htm).
- [GFXC. Global Index of Public Registers](https://www.globalfxc.org/global_index.htm).
- [RBI Press Release 2025-2026/1156. Renewal of the Statement of Commitment, 24 September 2025](https://www.rbi.org.in/Scripts/BS_PressReleaseDisplay.aspx?prid=61272).
Update history
- First published.