A S BANKA ADVISORS

On June 24, 2026, the Reserve Bank of India carried out one of the largest housekeeping exercises in the history of India’s foreign-exchange framework. Through A.P. (DIR Series) Circular No. 18 (reference RBI/2026-27/175), the RBI formally withdrew 732 circulars issued under the Foreign Exchange Management Act, 1999 since June 2000. If you run FDI, ODI, ECB or remittance compliance for a startup, an MSME or a corporate group, the question landing on your desk this week is simple: do I now have to do anything differently? The short answer is no. The longer answer is where founders get caught out, and that is what this advisory unpacks.

A withdrawal is not a rule change

This is the single most important point. The 732 circulars were withdrawn because they had already become inoperative through later amendments, redundancy, overlap, or supersession by newer Master Directions. The RBI itself calls it a rationalisation and simplification drive, not a policy shift. Your substantive limits are exactly where they were:

• Inbound FDI continues under the FEM (Non-debt Instruments) Rules, 2019 and the Master Direction on Foreign Investment. Sectoral caps and entry routes are unchanged.
• Outbound investment (ODI) continues under the FEM (Overseas Investment) Rules and Regulations, 2022. The Annual Performance Report is still due by December 31 each year, filed through Form FC.
• External Commercial Borrowings continue under the ECB Master Direction. Ceilings, end-use rules and the all-in-cost ceiling are unchanged.
• Resident remittances stay under the Liberalised Remittance Scheme Master Direction. The USD 250,000 per financial year limit stands.

So what is the real risk?

Nothing about your transactions changes. The risk is documentary. The two largest blocks withdrawn were roughly 120 pre-2019 ECB policy circulars and around 110 Exim Bank line-of-credit notifications, alongside 60-plus FDI circulars, about 50 AML and KYC instructions, and the older NRI, EEFC and LRS notifications. If your compliance manual, your board-approved FEMA policy, your filing checklists or your standard advisory templates still cite one of these 732 circulars by number, those references are now dead links. A regulator, a banker or an acquirer’s due-diligence team reading your policy will see you anchoring to a circular that no longer exists. That is an avoidable credibility problem during a fundraise or an audit.

A companion reform you should not miss

On the same day, the RBI issued A.P. (DIR Series) Circular No. 17, titled “Modification of Returns / Reporting requirements under FEMA, 1999.” Read together, Circulars 17 and 18 are a coordinated clean-up of both the instruction archive and the reporting machinery, and they follow the migration of certain FEMA returns to the RBI’s Centralised Information Management System (CIMS) portal. The direction of travel is clear: a Master-Direction-first, portal-filed FEMA stack. Your internal references should reflect that.

Your four-step action plan

1. Inventory. Pull every FEMA circular citation in your compliance manual, board policies and filing templates.
2. Cross-check. Match each citation against the RBI’s Excel annex to Circular 18 to find dead references.
3. Re-cite. Replace each withdrawn circular number with the surviving Master Direction.
4. Confirm. Reassure your board that no FDI, ODI, ECB or LRS limit has moved. Only the citation source has.

Used well, this is a free opportunity to modernise your cross-border compliance documentation before your next FC-GPR, Form FC or ECB filing. Used carelessly, it leaves dead law sitting in your policies for an auditor to find.

Download the full carousel PDF for the category-wise breakdown of the 732 withdrawn circulars and the action checklist.

Need help navigating this for your FDI or ODI structure? Talk to an Expert. Book a quick call: https://calendly.com/asbanka-info/30min CA Adityavikram Banka, Founder, A S Banka Advisors Private Limited.