SEBI’s non-agricultural commodity position-limit review and its proposal for phased physical settlement are separate policy tracks. The settlement proposal concerns select agricultural contracts; the evidence available here does not establish that SEBI raised non-agri position limits or specify what its September 2026 circular changed.
What is SEBI reviewing for non-agricultural contracts?
A position limit is a cap on the open positions a participant may hold. The applicable limit depends on the participant category and the governing rules, so the category and calculation basis matter as much as the headline figure.
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.” He described greater institutional participation as a way to improve liquidity and make the market more attractive for hedging, but did not announce a specific increase in limits. SEBI chairman’s address, December 20, 2025
SEBI’s listing records a September 9, 2026 circular titled “Review of Position Limits for Clients and Penalty Provisions for Violation / Breach of Position Limits for Commodity Derivatives Segment.” Its circular number is HO/47/16/13(5)2026-MRD-POD1/I/20735/2026. The listing confirms the circular’s title and date, but not its operative provisions. The title alone cannot establish whether non-agri limits changed, which participant categories are affected, how positions are monitored, what exemptions apply, or when any change takes effect. SEBI circular listing, September 9, 2026
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What does phased physical settlement mean?
In a financially settled contract, the obligation is settled in money rather than by delivering the underlying commodity. In physical settlement, delivery of the commodity is part of fulfilling the contract. SEBI’s May 12, 2026 consultation proposed a temporary financial-settlement phase for certain agricultural delivery-based contracts, followed by mandatory physical settlement when a specified trigger is reached. It is not a general settlement change for non-agricultural contracts. SEBI consultation on phased physical settlement, May 12, 2026
How the proposed transition would work
- An exchange could revive an illiquid delivery-based contract or launch a new one for a selected agricultural commodity.
- The contract could begin with financial settlement, while its delivery specifications would be in place from inception.
- Mandatory physical settlement would begin after the specified Average Daily Traded Volume (ADTV) and/or open-interest threshold is crossed, or two years from expiry of the relevant contract period, whichever occurs first.
The consultation presents this as a transitional route intended to help a thin or new contract develop liquidity and participation while retaining physical delivery as the eventual settlement method. Maize, groundnut and chilli are examples of possible pilot commodities, not confirmed selections. SEBI invited views on the proposal, risk safeguards, suitable commodities and alternatives; the consultation’s comment deadline was June 2, 2026. A consultation is not, by itself, an implemented rule. SEBI consultation paper
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How the two policy tracks differ
| Policy track | What it concerns | What is established |
|---|---|---|
| Non-agri position-limit review | Caps on open positions in non-agricultural commodity derivatives | SEBI’s chairman announced a working-group review in December 2025. A September 9, 2026 circular listing confirms a circular title, but the listing alone does not establish the operative limits or effective date. |
| Phased physical-settlement proposal | Settlement design for select agricultural commodity derivatives | A May 2026 consultation proposed a financial-settlement phase followed by physical settlement at specified triggers. The consultation does not confirm which pilot commodities, if any, were selected for implementation. |
| Client-limit and penalty consultation | Proposed client limits for agri derivatives and penalties for position-limit breaches | The paper discusses agri client-limit changes and penalties for breaches across agri and non-agri commodity derivatives; it is not evidence of a proposed increase in non-agri client limits. |
The May 12 client-limit consultation should not be conflated with the agricultural settlement paper or used to infer an increase in non-agri client caps. Its stated scope distinguishes agri client-limit changes from breach penalties that cover both agricultural and non-agricultural derivatives. SEBI consultation on client position limits and penalties, May 12, 2026
What the market figures do—and do not—show
In his December 20, 2025 address, the SEBI chairman said 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 also cited ₹580 trillion in annual notional turnover in FY 2024–25 and ₹628 trillion in notional turnover as of October 31, 2025, drawing on SEBI’s Annual Report and November 2025 bulletin. These figures describe market scale; they do not establish a position-limit change or prove that a settlement proposal was implemented. SEBI chairman’s address, December 20, 2025
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What to verify before relying on a claimed limit change
For a definitive account of any non-agri limit change, the operative circular text—not its listing title—is needed. It should be checked for the limit values, covered participant categories, measurement and monitoring basis, exemptions, and commencement date. SEBI’s commodity-derivatives listings provide a place to locate official notices, but a listing entry should not be treated as a substitute for the circular’s provisions. SEBI commodity-derivatives listings
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