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commodity derivatives

SEBI’s Non-Agri Position-Limit Review and Phased Settlement Proposal, Explained

SEBI’s non-agri position-limit review is separate from its proposal to phase in physical settlement for selected agricultural commodity contracts. Here is what the official record confirms—and what still depends on the circular’s full text.

By TheFinanceBase Team 4 min read

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SEBI’s non-agricultural position-limit review and its proposal for phased physical settlement are separate policy tracks. The available official record confirms a September 9, 2026 circular on client position limits and penalties, but its listing alone does not show whether non-agri limits increased or when any change takes effect. The phased-settlement proposal, meanwhile, concerns select agricultural contracts—not non-agricultural ones—and was issued for consultation.

What SEBI has—and has not—confirmed about non-agri position limits

A position limit is a cap on the open positions a participant may hold in a commodity derivatives contract. The relevant cap can depend on the participant category and the applicable rules; the phrase “higher limits” should not be read as a confirmed change without the operative circular.

On December 20, 2025, SEBI Chairman Tuhin Kanta Pandey said: “The Working Group to review the non-agri commodity derivatives segment will be notified shortly.” His address linked greater institutional participation with the goal of improving liquidity and making the market more attractive for hedging, but it did not announce higher non-agri position limits.

SEBI’s September 9, 2026 listing confirms a circular titled “Review of Position Limits for Clients and Penalty Provisions for Violation / Breach of Position Limits for Commodity Derivatives Segment,” number HO/47/16/13(5)2026-MRD-POD1/I/20735/2026. The listing does not provide the circular’s operative provisions. It therefore cannot establish whether non-agri limits changed, which participant categories are affected, how limits are monitored, whether exemptions apply, or the commencement date. Those details require the full circular, not an inference from its title.

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What the phased physical-settlement proposal covers

SEBI’s May 12, 2026 consultation proposes a route for exchanges to revive illiquid or launch new delivery-based contracts in select agricultural commodities. A contract could begin with financial settlement and move to mandatory physical settlement after predefined thresholds are crossed, or after two years from expiry of the relevant contract period, whichever comes first. The proposal describes the financial-settlement stage as transitional, with delivery specifications in place from the contract’s inception.

The proposed exemption from mandatory physical settlement would end when the specified Average Daily Traded Volume (ADTV) and/or open-interest threshold is crossed, or at the two-year time limit, whichever occurs earlier. The consultation mentions maize, groundnut, and chilli as possible pilot commodities. They are examples, not confirmed selections.

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SEBI’s stated policy balance is to give a new or thinly traded agricultural contract time to build participation and liquidity while retaining physical delivery as the eventual settlement method. The consultation sought views on whether the approach is appropriate, what safeguards are needed, which commodities could suit it, and what alternatives might work. Its comment deadline was June 2, 2026; the consultation itself is not an implementation decision.

How the two policy tracks differ

Policy track Subject What the official material establishes
Non-agri review Position limits in the non-agricultural commodity-derivatives segment SEBI’s December 2025 address said a working group would be notified shortly. The September 9, 2026 circular listing confirms a review title, but not the operative changes or effective date.
Phased settlement proposal Settlement design for select agricultural delivery-based contracts The May 12, 2026 consultation proposed financial settlement at first, followed by mandatory physical settlement at a specified activity threshold or the two-year time limit, whichever comes first.
Client-limit and penalty consultation Client limits and breach penalties The May 12 consultation described proposed client-limit changes for agricultural derivatives and separately discussed penalties for breaches across agricultural and non-agricultural commodity derivatives.

The agricultural client-limit proposals and the broader penalty discussion should not be conflated: the former do not establish a proposed increase to non-agri client limits. Nor does a proposal for temporary financial settlement in selected agricultural contracts imply a settlement change for non-agri contracts.

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Why the distinction matters to traders and hedgers

Position limits govern how large an open derivatives position may be; settlement rules govern how a contract is concluded. A limit change could affect the capacity of particular participants to hold positions, while a move from financial to physical settlement can create delivery-related obligations for participants in the specified contracts. Neither policy subject, by itself, confirms the details of the other.

For any eventual phased-settlement rule, the important design questions include whether liquidity and open-interest triggers are objective, how delivery specifications and warehousing readiness support the contract, what risk controls apply during the financial phase, and how the transition relates to convergence with the physical market price. The consultation raises a framework for those questions; it does not establish the final thresholds or pilot contracts.

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Market context in SEBI’s December 2025 address

SEBI’s December 20, 2025 address reported that 104 distinct commodities and variants had been notified for trading on recognized stock exchanges, while 34 unique commodities were available for trading: 23 agricultural and 11 non-agricultural. The address cited annual notional turnover of ₹580 trillion in FY 2024–25 and notional turnover of ₹628 trillion as of October 31, 2025, drawing on SEBI’s Annual Report and November 2025 bulletin. These figures describe market scale; they do not indicate that position limits were increased.

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