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RBI risks confusing reserve accumulation with resilience as quasi-sovereign FX mobilisation threatens to create future liabilities instead of lasting stability.


Venkat Thiagarajan is a currency market veteran.
May 7, 2026 at 12:48 PM IST
There are increasing market expectations that the Reserve Bank of India is exploring mechanisms to mobilise dollar inflows to bolster foreign exchange reserves and cushion renewed pressure on the rupee from elevated oil prices and persistent external-sector stress. The logic is understandable. The problem is that India may be preparing to recycle a 2013-era playbook for a very different macroeconomic environment.
History shows that applying the same financial engineering to every external shock rarely works for long. Previous crisis responses may provide a template, but every balance-of-payments episode emerges from a different combination of global liquidity conditions, domestic vulnerabilities and investor psychology. India’s successful efforts to stabilise the rupee and rebuild reserves during the 2013 taper tantrum cannot automatically be transplanted into the current environment, where both the scale and nature of external pressures are materially different.
The temptation to rely on offshore dollar mobilisation is also understandable because modern financial crises rarely announce themselves in advance. Fragility remains an inherent feature of market-based financial systems despite increasingly sophisticated risk-management frameworks and tighter regulation. If anything, the frequency of global financial dislocations over the past two decades has demonstrated how difficult it is to diversify systemic risk when confidence begins to erode.
India’s external-sector pressures today are not merely about currency volatility. They reflect a broader concern over the sustainability and financing quality of the balance of payments. The Reserve Bank has already intervened aggressively through both onshore and offshore dollar sales while simultaneously deploying regulatory measures to moderate pressure on the rupee.
The balance of payments remains sustainable only when a country can meet its external obligations over time without suppressing domestic economic activity or imposing artificial import compression. Persistent deficits are not automatically destabilising. Reserve currency economies such as the US can sustain very large imbalances because markets retain confidence in their financing capacity. Emerging markets operate under a narrower margin for error. Their external deficits remain manageable only as long as reserve adequacy, investor confidence and financing durability remain intact.
The global economy has learned much more about sudden stops and capital flow reversals since the Asian financial crisis. Foreign exchange reserves are now widely viewed as an essential insurance mechanism against disorderly adjustments. Yet reserve accumulation becomes less reassuring when it is accompanied by rising external liabilities and hidden contingent exposures.
Hidden Risks
That is where the current debate becomes more complicated. Using public sector banks as quasi-sovereign conduits for raising foreign currency resources may temporarily improve reserve optics, but it does not necessarily strengthen the underlying balance sheet of the economy.
The broader risk is that India could end up borrowing dollars to defend against structural pressures that require domestic adjustment rather than external financing. Persistent balance-of-payments deficits are typically addressed through some combination of fiscal restraint, monetary tightening or exchange-rate adjustment.
A fiscal approach to expenditure reduction would involve either reducing public spending in the economy, raising direct taxes, or a combination of both to address perennial balance-of-payments deficits.
A monetary approach would involve increasing interest rates or reducing the money supply to compress domestic demand and moderate import intensity. Currency depreciation, meanwhile, works through an “expenditure switching” process, where a fall in the currency encourages domestic consumers to substitute towards locally-produced goods and overseas consumers to shift towards cheaper exports from the depreciating economy.
By contrast, raising offshore dollar liabilities to finance recurring external gaps risks postponing adjustment rather than resolving it. Such strategies can gradually evolve into rollover-dependent frameworks where stability depends less on macroeconomic fundamentals and more on continuous investor appetite.
India would not be entering entirely unfamiliar territory. Brazil and Turkey experimented with comparable approaches during periods of external stress. Brazil relied on sovereign foreign-currency borrowing to inject liquidity and support the real. Turkey used foreign-exchange-protected deposits to slow domestic dollarisation. Both measures bought temporary stability. Neither resolved the underlying vulnerabilities, and both eventually generated significant fiscal and credibility costs.
Funding Routes
If India eventually moves towards structured offshore dollar mobilisation, the most likely route would involve securities issuance under Regulation S and Rule 144A frameworks. Regulation S remains the most widely used path for non-US issuers seeking to raise capital outside the United States because securities sold offshore are exempt from SEC registration requirements, provided there are no direct selling efforts within the US market.
Rule 144A provides a parallel route into deep pools of institutional liquidity within the US by allowing issuers to privately place securities with Qualified Institutional Buyers, including pension funds, insurers and large asset managers. The process is materially faster than a full public listing and involves comparatively lighter disclosure requirements through an offering circular rather than a full SEC-registered prospectus.
A third route would involve full registration through an F-1 filing for listing on exchanges such as the NYSE or NASDAQ. That route requires audited financial statements, detailed risk disclosures and, in many cases, reconciliation with US accounting standards. Operationally, therefore, offshore dollar raising is entirely feasible for Indian issuers if policymakers decide to activate such a window.
The broad contours would likely resemble previous emerging-market issuance programmes where benchmark-sized Regulation S and Rule 144A tranches are sold to sovereign wealth funds, emerging-market bond funds and Asian reserve managers.
If the Reserve Bank opens a window for foreign-currency mobilisation through public sector banks, markets are unlikely to treat those liabilities as fully independent from the sovereign. Investors effectively view such borrowings as indirect sovereign obligations, particularly if the central bank provides hedging support or implicit currency backstops.
India’s own past efforts to mobilise foreign-currency resources through public sector banks also illustrate how such mechanisms function more as temporary stabilisation tools than as durable external-sector solutions.
|
Mode of Raising USD Resources |
Broad Structure |
Underlying Concern |
|---|---|---|
|
FCNR(B) deposits |
Banks mobilise foreign-currency deposits from non-resident Indians with swap support from RBI |
Creates contingent central bank liabilities if currency pressures intensify |
|
Offshore bond issuance |
Public sector banks or quasi-sovereign entities raise dollar debt overseas |
Markets often treat borrowings as sovereign-linked exposure |
|
Special dollar windows |
RBI provides swap or concessional facilities to incentivise inflows |
Improves short-term reserve optics without correcting structural imbalances |
That creates a more uncomfortable question for policymakers. If the rupee weakens materially over time, who ultimately absorbs the currency risk? The answer may quietly migrate back to the sovereign balance sheet or the Reserve Bank itself.
Such contingent liabilities matter because they blur fiscal transparency while creating the appearance of stronger reserve adequacy. Foreign exchange buffers built on borrowed dollars are fundamentally different from reserves accumulated through durable current-account strength or long-term capital inflows.
None of this means the Reserve Bank should remain passive during periods of external stress. Central banks are expected to smooth volatility and preserve orderly market functioning. Yet there is an important distinction between crisis management and balance-sheet substitution.
Using public sector banks to mobilise offshore dollars may buy India time, stabilise sentiment and reduce near-term pressure on the rupee. It cannot substitute for deeper structural reforms that improve export competitiveness, attract stable capital flows and strengthen the long-term resilience of the external account.
That is the real policy challenge confronting the Reserve Bank. Markets may initially celebrate higher reserves and temporary currency stability. Over time, however, investors also begin to examine the liabilities sitting beneath those buffers.
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