Sebi Proposes Netting of Funds for FPIs in Cash Market to Reduce Funding Costs
Sebi has proposed a netting mechanism for FPI cash market transactions to reduce funding costs and improve operational efficiency. The proposal allows FPIs to use sale proceeds to fund same-day purchases, addressing current gross settlement requirements that increase liquidity needs and funding costs, particularly during index rebalancing periods.

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The Securities and Exchange Board of India (Sebi) has proposed permitting netting of funds for cash market transactions by Foreign Portfolio Investors (FPIs), a move aimed at reducing funding costs and improving operational efficiency, particularly during high-volume trading days such as index rebalancing. The regulator has invited public comments until February 6, 2026.
Current Settlement Framework Challenges
Under the existing system, FPIs are required to bring in full funds for purchases irrespective of sales on the same day, even though custodians eventually settle their obligations with clearing corporations on a net basis. This results in higher liquidity requirements and funding costs for investors, often leaving FPIs "underinvested" for at least a day.
| Current System Issues: | Impact |
|---|---|
| Gross Settlement Requirement: | Each trade settled individually |
| Additional Funding Cost: | At least one extra day of funding |
| Forex Slippage Risk: | Costs from buying/selling forex separately |
| Operational Inefficiency: | Complex settlement procedures |
Sebi illustrated the problem with an example: "Suppose an FPI has purchased stock A worth ₹100.00 crore and sold stock B worth ₹100.00 crore. The FPI would still need to make available ₹100.00 crore towards the purchase," adding that the amount could otherwise have been adjusted against sale proceeds. The issue becomes more pronounced during index rebalancing, when FPIs typically see large simultaneous inflows and outflows, with funding costs increasing significantly.
Proposed Netting Mechanism
Under the proposal, FPIs would be allowed to use sale proceeds from cash market transactions on a given day to fund purchases executed on the same day, thereby meeting only their net fund obligation instead of settling all trades on a gross basis. The proposed netting of funds refers to using proceeds from sale transactions to fund purchase transactions executed by an FPI on the same day.
| Transaction Type: | Settlement Method |
|---|---|
| Outright Transactions: | Eligible for netting |
| Non-Outright Transactions: | Gross settlement (current system) |
| Intra-day Same Security: | Excluded from netting |
| Mixed Buy/Sell Same Security: | Gross settlement maintained |
The regulator has specified that only "outright" transactions, where an FPI has either a buy or a sell position in a security in a settlement cycle, but not both, will be eligible for fund netting. Trades involving both buy and sell positions in the same security will continue to be settled on a gross basis, effectively excluding intra-day round-tripping from the benefit.
Implementation Framework and Safeguards
Sebi has outlined specific scenarios for fund obligations. If the value of outright sell transactions does not exceed outright buy transactions, the residual amount, along with non-outright buy obligations, would be funded by the FPI. However, if outright sell value exceeds outright buy value, the excess outright sell amount would not be adjusted towards non-outright buy obligations.
The regulator acknowledged concerns raised by custodians and clearing corporations, including the risk of higher trade rejections and increased settlement risk. Sebi emphasized that robust safeguards already exist, stating: "Necessary safeguards by way of default waterfall mechanism, Core Settlement Guarantee Fund (Core SGF), etc., have been put in place." The regulator noted that netting could actually reduce the likelihood of fund-related trade rejections.
Market Impact and Regulatory Changes
Sebi clarified that securities settlement would continue on a gross basis between FPIs and custodians, ensuring that Securities Transaction Tax (STT) and stamp duty would continue to be charged on a delivery basis. There would be no change in the settlement process between custodians and clearing corporations.
| Implementation Aspects: | Details |
|---|---|
| System Upgrades: | Custodians required to upgrade systems |
| Regulatory Changes: | Amendments to Sebi and RBI frameworks |
| Tax Impact: | STT and stamp duty unchanged |
| Settlement Risk: | No increase in market risk |
The proposal will require amendments to regulatory frameworks issued by Sebi and the Reserve Bank of India, with custodians required to upgrade systems to support the new framework. If implemented, the regulator said the move would lower funding costs for FPIs without increasing market risk, as non-outright transactions would continue to be settled on a gross basis to prevent undue market influence.














































