The Reserve Bank of India has quietly asked some banks to change the way they value a large slice of their bond derivative trades, a move that could squeeze treasury profits and put dividend payouts under closer watch. The instruction came during routine supervisory audits in recent weeks, according to a Bloomberg report first published by Moneycontrol on November 9, and it covers bond-forward contracts worth around Rs 1.1 lakh crore across the banking system.
No formal circular has been issued, and the banks involved have not been named. But the message is clear: trades whose prices cannot be checked against a live market should be valued using banks’ own models, not quotes that do not really exist.
What are bond forwards, and who uses them
A bond forward is a simple deal at heart. A bank agrees today to sell a government bond at a fixed price on a future date. The buyer, usually an insurer, uses the contract to lock in a price and protect itself against swings in interest rates.
Banks sit on the other side of these trades as part of their treasury operations. Clearinghouse data cited in the report puts the notional value of outstanding bond-forward trades at about Rs 1.1 lakh crore, or roughly $11 billion, this year. That is the face value of the contracts, not the profit or loss sitting on them, but it shows how large this corner of the market has become.

What Level 3 valuation actually means
Accounting rules sort financial instruments by how easy they are to value. Level 1 covers assets with a quoted price in an active market. Level 2 uses observable inputs, like similar bonds trading nearby. Level 3 is the last rung: the value cannot be checked against observable market information, so the bank must rely on its own models and assumptions.
The RBI’s position, as reported, is that bond forwards belong in Level 3. There is no deep, liquid market in these contracts with prices flashing on a screen, so a bank marking them to a supposed market price is dressing up a model-based estimate as something more solid. Moving them to Level 3 forces banks to be honest about that uncertainty. Level 3 does not mean an asset is bad or distressed. It is a statement about how reliably the value can be measured, not about whether the trade will make or lose money.
Why it matters for profits, capital and dividends
The reclassification has three practical consequences for the banks concerned.
- Treasury profits: How a trade is valued decides how much gain or loss shows up in the profit and loss account. A stricter method can trim reported treasury income.
- Regulatory capital: Under RBI rules, Level 3 classification can leave a bank with less regulatory capital against the same trades, because the regulator applies a more cautious treatment to hard-to-value positions.
- Dividends: The same rules can force banks to limit dividend payouts. A bank that wants to return cash to shareholders needs the capital headroom to do it, and a Level 3 tag eats into that headroom.
None of this means banks are in trouble. It means the regulator wants the risk in these trades priced and reported more conservatively.
What banks are doing about it
Banks have not pushed back in public. Instead, they have taken the issue to the Fixed Income Money Market and Derivatives Association of India, or FIMMDA, the industry body for the bond and derivatives market, and are seeking a common approach and clearer guidance.
Lenders have also held informal talks with the Clearing Corporation of India, which runs the trade repository for these deals, about providing better pricing information. The Clearing Corporation is testing an electronic trading platform for bond forwards, which could bring more transparency and, over time, the observable prices that would make the Level 3 question less pressing.
What happens next
Three things are worth watching. First, whether the RBI turns its audit-room view into a written circular, which would make the treatment uniform across all banks. Second, whether FIMMDA and the Clearing Corporation can agree on a pricing standard that gives the market the observable inputs it currently lacks. And third, how banks reflect the change in their December quarter results.
FAQs
What is a bond forward?
A contract in which a bank agrees to sell a bond at a fixed price on a future date. Insurers use it to lock in bond prices and hedge interest-rate risk.
What does Level 3 valuation mean?
A trade’s value cannot be checked against observable market prices, so the bank must use its own models and assumptions to value it.
How big is India’s bond-forward market?
Clearinghouse data cited in the reports puts the notional value of outstanding trades at around Rs 1.1 lakh crore, or about $11 billion, this year.
Will this affect bank dividends?
It could. Level 3 classification can reduce regulatory capital headroom, which can in turn limit how much a bank can pay out as dividends.
Has the RBI issued a formal circular on this?
No. The position was communicated during supervisory audits, and no separate circular has been issued so far.
The RBI’s audit-room instruction is a reminder that supervision often works quietly. Whether it becomes a formal rule, and how much it costs banks, will show up in the months ahead.

