RBI considers fresh Full Fledged Money Changer (FFMC) licence applications only if they were already under process on 6 May 2026. The document checklist for those applications is set out in the Annex to Regulation 3(6) of the Foreign Exchange Management (Authorised Persons) Regulations, 2026. Existing FFMCs follow a separate renewal process under Regulation 5. A new business planning to offer retail currency exchange can explore appointment as a Forex Correspondent through an eligible Authorised Dealer.

The first step is to identify which route applies to your business. A company with a pending FFMC application may need a statutory auditor’s certificate and a confidential banker’s report. An existing FFMC preparing for renewal needs to check its licence expiry and net worth. A business exploring Forex Correspondent appointment should obtain the onboarding checklist from the Authorised Dealer it plans to work with.

In this article, CA Manish Mishra talks about Documents Required for FFMC Registration in India.

Documents Required for Pending FFMC Applications

Company Documents and Board Resolution

Start with the Certificate of Incorporation, Memorandum of Association (MOA) and Articles of Association (AOA). Identify the clause that covers money-changing business. If the company amended its objects after incorporation, keep the updated document and filing acknowledgement together. This makes it easier to show when the company added the activity.

The board resolution should record the company’s decision to undertake money changing. Check that the legal name on the resolution matches the application, audited accounts and banker’s report. If the resolution identifies an authorised signatory, confirm that the person handling the RBI correspondence has the authority to do so.

Audited Accounts and Net Owned Funds Certificate

For pending applications covered by the Annex, the minimum Net Owned Funds are ₹25 lakh for a single branch and ₹50 lakh for multiple branches. The company’s statutory auditor certifies the NOF as of the application date. The company should also provide its latest audited accounts and the previous three years of audited balance sheets and profit and loss accounts, wherever applicable.

Paid-up capital is only one part of the NOF calculation. For example, suppose a company proposes a single branch and has ₹30 lakh in paid-up equity and ₹7 lakh in accumulated losses, with no other relevant balances or adjustments. Its NOF would be ₹23 lakh, which is below the ₹25 lakh requirement. An auditor’s reconciliation helps explain how the figures in the accounts lead to the certified amount.

If the company has fewer than three completed financial years, identify which audited statements are available. The three-year requirement applies wherever relevant. The Annex separately calls for the latest audited accounts and the statutory auditor’s NOF certificate.

Confidential Banker’s Report

Ask the applicant company’s banker for the confidential report specified in the Annex. Give the banker the company’s legal name and RBI application reference so it can identify the case. The Annex calls for the report in a sealed cover. Follow the instructions issued by the RBI office handling the application for delivery of confidential material.

A bank statement shows account activity and balances. The confidential banker’s report serves a separate purpose and is listed separately in the prescribed checklist.

Enforcement Declarations and Director Records

The applicant’s declaration covers proceedings initiated or pending with the Directorate of Enforcement, the Directorate of Revenue Intelligence or other law enforcement authorities, as well as the specified criminal cases involving the company or its directors. Check the facts for each director before signing. If a matter exists, disclose its status accurately and provide supporting records where required.

The company also needs to assess whether its directors meet the applicable fit-and-proper criteria. This review considers their qualifications, experience, track record and integrity. Keep the signed director declarations and the record of the nomination committee’s review together so the company can explain how it assessed suitability if RBI asks.

KYC Declaration and Group Company Details

The KYC declaration records the company’s commitment to put the required customer verification policy in place before operations begin. When preparing the policy, assign responsibility for verifying customers, maintaining transaction records and escalating unusual activity. These procedures help staff apply the policy consistently at the counter.

The company should also disclose sister or associated concerns that operate in the financial sector. For example, if the applicant and an NBFC share a parent company, identify the NBFC and explain the relationship. Review the disclosure alongside the financial records because certain group exposures can affect the NOF calculation.

How to Respond to an RBI Request for Additional Documents

Locate the original acknowledgement and the latest RBI communication. List each question and identify the document that answers it. If RBI asks why the NOF certificate differs from a figure in the balance sheet, provide the signed certificate and a reconciliation showing the adjustments. If it asks about the company’s objects, identify the relevant MOA clause and attach the filed amendment where applicable.

For applications covered by Regulation 3(6), where RBI had sought additional information or documents, the applicant had 30 days from the date the regulations took effect to provide them. The regulation provides for deemed rejection if the deadline was missed. Check the original correspondence and proof of submission to establish the status of the application.

Documents for FFMC Licence Renewal

An existing FFMC should apply for renewal at least two months before its authorisation expires. If it applies within the prescribed period, the existing authorisation continues until RBI grants renewal or rejects the application. Regulation 5 requires minimum net worth of ₹25 lakh for a single branch and ₹50 lakh for multiple branches, along with the applicable fit-and-proper and enforcement-related conditions.

Keep the existing authorisation, current financial evidence, branch details and records relating to promoters, directors and key managerial personnel ready. Use the current renewal form and instructions to confirm the exact attachments. The same rupee amounts apply to both routes, but the financial measures differ. Renewal uses net worth under Regulation 5. Pending fresh FFMC applications use NOF under the Annex. Ask the auditor to calculate the figure required for the relevant route.

Documents for Forex Correspondent Onboarding

A business planning to open a new retail currency exchange counter can approach an AD Category-I or AD Category-II entity about becoming a Forex Correspondent. The Authorised Dealer sets its onboarding criteria under a board-approved policy. These criteria can cover the type of entity, net worth, due diligence, operating controls and customer service.

For the initial discussion, keep the entity and ownership records, financial statements, proposed outlet details and a brief description of the planned operations ready. The Authorised Dealer will specify which documents it needs and, if it appoints the business, issue permission for each approved outlet.

Conclusion

For a pending FFMC application, organise the company records, statutory auditor’s NOF certificate, confidential banker’s report and director declarations around the original RBI reference. Check that names, dates and financial figures match across the documents. If RBI has asked for clarification, answer each point with the document that supports it.

Existing FFMCs should work backwards from the licence expiry date and prepare the financial and eligibility records needed for renewal. A business opening its first currency exchange counter should request the prospective Authorised Dealer’s Forex Correspondent checklist before arranging certificates or committing to a location.

Frequently Asked Questions (FAQ’s)

Q1. Can a newly incorporated company apply for a fresh FFMC licence in 2026?

Ans. RBI considers fresh FFMC applications only if they were already under process on 6 May 2026. A new company that plans to offer retail currency exchange can approach an eligible Authorised Dealer for Forex Correspondent appointment.

Q2. Who issues the NOF certificate for a pending FFMC application?

Ans. The applicant company’s statutory auditor certifies Net Owned Funds as of the application date. Submit the certificate with the latest audited accounts.

Q3. Are three years of audited accounts required in every case?

Ans. The Annex calls for three years of audited balance sheets and profit and loss accounts wherever applicable. The latest audited accounts and the NOF certificate are separate requirements.

Q4. Can a bank statement replace the confidential banker’s report?

Ans. The Annex requires a separate confidential report from the applicant company’s banker and specifies a sealed cover. Follow the concerned RBI office’s delivery instructions.

Q5. Does submitting every document guarantee an FFMC licence?

Ans. RBI also considers eligibility and fit-and-proper status. The concerned Regional Office considers the case based on clearance from the Empowered Committee, and the final decision rests with RBI.

Q6. Is the same financial certificate used for a pending application and a renewal?

Ans. A pending application covered by the Annex requires a statutory auditor’s NOF certificate. A renewal is assessed against the applicable net worth threshold. Check the renewal form for the supporting evidence it requires.

Q7. What should I do if the company name differs across FFMC application documents?

Ans. Keep the certificate or official record of the name change ready. In your response to RBI, explain which documents show the former name and quote the original application reference.

Q8. What should a company submit if its MOA did not originally cover money changing?

Ans. If the company amended its objects to include money changing, keep the updated Memorandum of Association (MOA) and the relevant filing acknowledgement ready. Highlight the amended clause so RBI can locate it easily.

Q9. Which related companies should be disclosed in a pending FFMC application?

Ans. Disclose sister or associated concerns operating in the financial sector, including relevant NBFCs. Identify each entity and explain its relationship with the applicant, such as a shared parent company.

Q10. What documents should a business prepare for Forex Correspondent onboarding?

Ans. Keep incorporation and ownership records, financial statements, proposed outlet details and a brief description of the planned operations ready. Ask the prospective Authorised Dealer for its checklist, as it determines the exact documents required.