
RBI/2025-26/253 A.P. (DIR Series) Circular No. 25; Dated: 30.03.2026
The Reserve Bank of India (RBI) has issued important clarifications regarding the reporting framework and compliance requirements for External Commercial Borrowings (ECB).
1. Classification of ECB Forms as Non-Flow Returns
The RBI has clarified that Form ECB 1 and the revised Form ECB 1 shall be treated as non-flow returns. This implies that these forms are not part of periodic reporting flows but are event-based submissions.
2. Delay in Form ECB 2 and LSF Implications
Each delay in the submission of Form ECB 2 under a Loan Registration Number (LRN) will be considered as a separate instance for the purpose of calculating the Late Submission Fee (LSF).
This means that multiple delays, even under the same LRN, will attract separate penalties.
3. Timeline for Submission by AD Category I Banks
Authorised Dealer (AD) Category I banks are now required to submit duly certified ECB returns to the RBI within 7 days from the date of receipt of such returns from the borrower.
This introduces a stricter timeline to ensure timely regulatory reporting.
4. Payment of Late Submission Fee (LSF)
Any applicable Late Submission Fee (LSF) must be remitted to the concerned Regional Office of the RBI.
The payment is to be made through standard banking channels such as NEFT or RTGS.
5. Conclusion
These clarifications reinforce the RBI’s focus on timely compliance, accurate reporting, and stricter monitoring of ECB transactions, while also streamlining procedural aspects for both borrowers and AD banks.
Click Here To Read The Full Circular
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