If you are an NRI trading F&O in India, there has traditionally been an additional layer in the setup that resident traders do not deal with. One of those requirements was the Custodial Participant, or CP, Code. It meant additional coordination between the trader, broker, clearing member and exchange before you could get started.
SEBI has now removed the mandatory CP Code requirement for NRIs trading in exchange-traded derivatives. The change came through a circular dated 29 July 2025, with NRI position limits now being monitored at the client level instead. In practical terms, one operational step in the F&O setup is no longer mandatory.
A simpler F&O setup for NRI traders
Earlier, an NRI looking to trade F&O had to notify the exchange about the Clearing Member and obtain a CP Code as part of the setup. The CP Code was also used in the framework for monitoring positions taken by NRIs across the market. With SEBI moving the monitoring of applicable position limits to the client level, the CP Code itself no longer needs to be mandatory for this purpose.
Think of an NRI living in Dubai who has an NRO Non-PIS account and wants to trade NIFTY options through FYERS. Earlier, obtaining the CP Code formed part of the operational setup for F&O access. Under the revised framework, that mandatory step goes away. The trader still needs to meet the applicable requirements for activating and trading in F&O, but there is one less piece to coordinate.
At FYERS, eligible NRIs can trade equity F&O through an NRO Non-PIS account. If you want to check the current activation process and applicable charges, you can find the details here.
CP Code removal does not change the PIS framework
This is where we want to be very clear because it is easy to mix up the two. The removal of the mandatory CP Code does not mean that PIS has been removed.
The CP Code was part of the operational framework around NRI participation in exchange-traded derivatives. PIS and Non-PIS, on the other hand, relate to the investment and banking routes through which NRIs participate in Indian markets. These are separate parts of the overall setup.
For instance, an NRO Non-PIS account can be used for eligible F&O trading with FYERS. An NRE PIS account is primarily used for eligible repatriable equity investments under the applicable PIS framework. Removing the mandatory CP Code does not remove these NRE, NRO, PIS or Non-PIS distinctions. If you want to understand which segments NRIs can trade through FYERS, you can read more here.
The broader NRI framework remains unchanged
Most of the broader NRI framework remains unchanged. Your residential status, KYC requirements, bank account structure, FEMA requirements, eligible trading segments and the applicable SEBI, RBI, exchange, clearing corporation and tax requirements continue to matter.
There are also operational differences that NRIs should be aware of when trading equity delivery and F&O. For example, NRIs using an NRO Non-PIS account with FYERS currently need to maintain separate fund allocations for equity delivery and F&O.
So, this change is best understood for what it actually does. It removes one operational requirement from the NRI F&O process. It does not change the underlying framework through which NRIs invest and trade in India.
For us, that is still a useful improvement. If position limits can be monitored directly at the client level without requiring an additional code and another layer of coordination, the process becomes simpler without changing the regulatory objective behind it.
If you are an existing NRI client looking to activate F&O, or you are planning to open an NRO Non-PIS account with FYERS, you can check the latest NRI account requirements here.
The CP Code is no longer mandatory. The rest of the applicable NRI trading framework continues as before. What changes is that getting to the point where you can actually trade F&O now involves one less operational step.
As per the latest SEBI guidelines, CP is now optional for F&O trading through an NRO Non-PIS Demat account. This means you can trade directly through FYERS without the earlier CP funding and proof-submission process.