FEMA Guarantee Reporting Requirements and Forms

India RBI Notifications

Published April 1st, 2026

Detected April 2nd, 2026

Summary

The Reserve Bank of India issued A.P. (DIR Series) Circular No. 01 establishing new reporting requirements for guarantee transactions under FEMA (Guarantees) Regulations, 2026. Authorised dealer banks must report guarantee issuances, modifications, and invocations using three new forms (GRN Issue, GRN Modification, GRN Invocation) via the Centralised Information Management System within 30 calendar days of each quarter end. Each guarantee issuance requires a unique Guarantee Transaction Number.

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What changed

RBI has introduced three mandatory reporting forms under FEMA 8(R) for guarantee transactions: Form GRN Issue for new guarantee issuances, Form GRN Modification for changes to guarantee amount, extension of period, or pre-closure, and Form GRN Invocation for guarantee invocations. The circular requires authorised dealer banks to assign a unique Guarantee Transaction Number for each guarantee reported through Form GRN Issue and to submit all returns to RBI within 30 calendar days from the end of each quarter through the CIMS platform.

Authorised Persons and their customers with guarantee reporting obligations under Regulation 7 of FEMA 8(R) must implement these new procedures immediately. Banks acting as authorised dealers must ensure their reporting systems can generate unique transaction numbers and submit returns within the specified timeframe. For late submission fees on Form GRN Invocation, the liability amount is based on the surety obligation created upon invocation; for Form GRN Issue and Modification, no late fees apply as these do not capture financial flows. Non-compliance may result in late submission penalties as prescribed under FEMA.

What to do next

Implement the three new reporting forms (GRN Issue, GRN Modification, GRN Invocation) for guarantee transactions under FEMA 8(R)
Ensure unique Guarantee Transaction Numbers are generated for each guarantee issuance before RBI submission
Submit quarterly returns to RBI via CIMS (sankalan.rbi.org.in) within 30 calendar days of quarter end

Penalties

Late Submission Fees applicable for delayed reporting of Form GRN Invocation; fee calculation based on the amount of liability created towards surety on invocation

Source document (simplified)

Notifications

| () | |
| Reporting under Foreign Exchange Management Act, 1999 – Returns pertaining to Foreign Exchange Management (Guarantees) Regulations, 2026 | |
| | RBI/2026-27/02
A.P. (DIR Series) Circular No. 01

April 01, 2026

All Authorised Persons

Madam / Sir,

Reporting under Foreign Exchange Management Act, 1999 – Returns pertaining to
Foreign Exchange Management (Guarantees) Regulations, 2026

Attention of Authorised Persons is invited to Foreign Exchange Management (Guarantees) Regulations, 2026 [FEMA 8 (R)] and Master Direction – Reporting under Foreign Exchange Management Act, 1999.

A person having the obligation to report a guarantee in terms of Regulation 7 of FEMA 8 (R), may use the following files provided on the RBI website (List of Returns Submitted to RBI) for submissions to the authorised dealer bank:

a)‘Form GRN Issue’ – For reporting issuance of Guarantee.

b)‘Form GRN Modification’ – For reporting any subsequent change in guarantee terms, namely - guarantee amount, extension of period or pre-closure.

c)‘Form GRN Invocation’ – For reporting invocation of guarantee.

The authorised dealer bank shall thereby submit the returns to the Reserve Bank of India within thirty calendar days from the end of the respective quarter through Centralised Information Management System (CIMS) (URL: https://sankalan.rbi.org.in). Operational guidelines are being provided therein.
For each guarantee issuance, reported through ‘Form GRN Issue’, the authorised dealer bank shall provide a unique Guarantee Transaction Number before submission of the return to the Reserve Bank in the manner provided in the operational guidelines
For the purpose of computation of Late Submission Fees for delayed reporting of ‘Form GRN Invocation’, the amount involved in the delayed reporting (A) shall be the amount of liability created towards the surety on invocation. For Delayed reporting of ‘Form GRN Issue’ and ‘Form GRN Modification’, ‘A’ shall be considered to be ‘Nil’ since these returns do not capture flows.
Authorised Persons may bring the contents of the circular to the notice of their customers/ constituents concerned.
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.
These directions shall come into force with immediate effect.

Yours faithfully,

(Dr. Aditya Gaiha)
Chief General Manager-in-Charge | | RBI/2026-27/02
A.P. (DIR Series) Circular No. 01

April 01, 2026

All Authorised Persons

Madam / Sir,

Reporting under Foreign Exchange Management Act, 1999 – Returns pertaining to
Foreign Exchange Management (Guarantees) Regulations, 2026

Attention of Authorised Persons is invited to Foreign Exchange Management (Guarantees) Regulations, 2026 [FEMA 8 (R)] and Master Direction – Reporting under Foreign Exchange Management Act, 1999.

A person having the obligation to report a guarantee in terms of Regulation 7 of FEMA 8 (R), may use the following files provided on the RBI website (List of Returns Submitted to RBI) for submissions to the authorised dealer bank:

a)‘Form GRN Issue’ – For reporting issuance of Guarantee.

b)‘Form GRN Modification’ – For reporting any subsequent change in guarantee terms, namely - guarantee amount, extension of period or pre-closure.

c)‘Form GRN Invocation’ – For reporting invocation of guarantee.

The authorised dealer bank shall thereby submit the returns to the Reserve Bank of India within thirty calendar days from the end of the respective quarter through Centralised Information Management System (CIMS) (URL: https://sankalan.rbi.org.in). Operational guidelines are being provided therein.
For each guarantee issuance, reported through ‘Form GRN Issue’, the authorised dealer bank shall provide a unique Guarantee Transaction Number before submission of the return to the Reserve Bank in the manner provided in the operational guidelines
For the purpose of computation of Late Submission Fees for delayed reporting of ‘Form GRN Invocation’, the amount involved in the delayed reporting (A) shall be the amount of liability created towards the surety on invocation. For Delayed reporting of ‘Form GRN Issue’ and ‘Form GRN Modification’, ‘A’ shall be considered to be ‘Nil’ since these returns do not capture flows.
Authorised Persons may bring the contents of the circular to the notice of their customers/ constituents concerned.
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.
These directions shall come into force with immediate effect.

Yours faithfully,

(Dr. Aditya Gaiha)
Chief General Manager-in-Charge |
| RBI/2026-27/02
A.P. (DIR Series) Circular No. 01

April 01, 2026

All Authorised Persons

Madam / Sir,

Reporting under Foreign Exchange Management Act, 1999 – Returns pertaining to
Foreign Exchange Management (Guarantees) Regulations, 2026

Attention of Authorised Persons is invited to Foreign Exchange Management (Guarantees) Regulations, 2026 [FEMA 8 (R)] and Master Direction – Reporting under Foreign Exchange Management Act, 1999.

A person having the obligation to report a guarantee in terms of Regulation 7 of FEMA 8 (R), may use the following files provided on the RBI website (List of Returns Submitted to RBI) for submissions to the authorised dealer bank:

a)‘Form GRN Issue’ – For reporting issuance of Guarantee.

b)‘Form GRN Modification’ – For reporting any subsequent change in guarantee terms, namely - guarantee amount, extension of period or pre-closure.

c)‘Form GRN Invocation’ – For reporting invocation of guarantee.

The authorised dealer bank shall thereby submit the returns to the Reserve Bank of India within thirty calendar days from the end of the respective quarter through Centralised Information Management System (CIMS) (URL: https://sankalan.rbi.org.in). Operational guidelines are being provided therein.
For each guarantee issuance, reported through ‘Form GRN Issue’, the authorised dealer bank shall provide a unique Guarantee Transaction Number before submission of the return to the Reserve Bank in the manner provided in the operational guidelines
For the purpose of computation of Late Submission Fees for delayed reporting of ‘Form GRN Invocation’, the amount involved in the delayed reporting (A) shall be the amount of liability created towards the surety on invocation. For Delayed reporting of ‘Form GRN Issue’ and ‘Form GRN Modification’, ‘A’ shall be considered to be ‘Nil’ since these returns do not capture flows.
Authorised Persons may bring the contents of the circular to the notice of their customers/ constituents concerned.
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.
These directions shall come into force with immediate effect.

Yours faithfully,

(Dr. Aditya Gaiha)
Chief General Manager-in-Charge | |

Named provisions

Regulation 7 - FEMA 8(R) Reporting Obligation Section 10(4) FEMA 1999 Section 11(1) FEMA 1999 Section 11(2) FEMA 1999 Form GRN Issue Form GRN Modification Form GRN Invocation