NRO Repatriation 2026: USD 1 Million Rule & Forms 145/146

The money is yours. It has been sitting in your NRO account in Mumbai for years: rent from the flat, a couple of matured deposits, maybe the proceeds of a sale. You finally put in a request to move it to Toronto, or Dubai, or simply across to your NRE account.

And the bank writes back: “Kindly submit CA certificate and Form 15CA/15CB.”

Except that since 1 April 2026, those forms no longer exist under those names. The relationship manager may not have caught up. This article is the walk-through we wish every bank handed out: what the limit actually is, what replaced 15CA and 15CB, when you need a chartered accountant, and the eight reasons transfers get stuck at the branch.

Applies to: NRIs and OCIs remitting from NRO accounts · NRO-to-NRE transfers · Repatriation of rent, deposits, sale proceeds and inheritance

NRE vs NRO in sixty seconds

	NRE account	NRO account
What goes in	Money you earned abroad and sent to India	Money you earn in India: rent, interest, dividends, pension, sale proceeds, inheritance, gifts
Interest	Tax-free in India	Taxable; bank deducts TDS at 30% plus surcharge and cess
Sending money abroad	Freely repatriable, no limit, no tax forms in most cases	Up to USD 1 million per financial year, after tax compliance is proven
Moving between the two	NRE to NRO: any amount, any time, no forms	NRO to NRE: counts against the USD 1 million limit and needs the full paperwork

The entire subject of “repatriation” is really about that bottom-right box. India lets Indian-sourced money leave the country, but it asks two questions first: has the tax on it been paid, and where did it come from? Everything below is about answering those two questions in a form the bank will accept.

The USD 1 million rule, precisely

Under FEMA, an NRI or PIO may remit up to USD 1 million per financial year out of NRO balances. Some details that matter more than the headline number:

• It is per person, per financial year (1 April to 31 March), across all your NRO accounts combined, not per account or per bank.
• NRO-to-NRE transfers use up the same limit. Moving money to NRE is treated as repatriation, because once it is in NRE it can leave freely.
• Unused limit does not carry forward. If you need to move more than a million dollars, the standard approach is to split it across two financial years: one tranche in March, one in April.
• You should route it through one authorised dealer bank in a year. Banks track your cumulative use of the limit, and they cannot see what another bank has already processed.
• What counts: balances accumulated in NRO, sale proceeds of property or investments, inheritance and legacies, rent, pension, deposits, gifts from relatives. The source has to be legitimate and documented, which is the second half of the paperwork.

And one reassurance, because we get asked constantly: the TCS you have read about on foreign remittances applies to residents sending money under the Liberalised Remittance Scheme. NRO repatriation runs under a different scheme. There is no TCS on it.

What changed on 1 April 2026: Form 145 and Form 146

For over a decade, every taxable remittance to a non-resident needed two documents: Form 15CA, a declaration by the person sending the money, and Form 15CB, a certificate from a chartered accountant confirming that tax on the money had been correctly dealt with.

The Income-tax Act, 2025 renumbered the entire law, and the forms went with it:

Old (until 31 March 2026)	New (from 1 April 2026)	What it is
Form 15CA	Form 145	Your online declaration, filed on the e-filing portal before the remittance
Form 15CB	Form 146	The chartered accountant’s certificate, with a UDIN, uploaded to the portal before Form 145 is filed
Section 195	Section 393	The provision that requires tax to be deducted on payments to non-residents
Rule 37BB	Rule 220	The rule that sets out when each part applies and the ₹5 lakh threshold

What did not change: the purpose, the thresholds, the sequence, or the fact that the bank will not move a rupee until it has the acknowledgements in hand. The date that matters is the date of remittance. Anything remitted on or after 1 April 2026 uses Forms 145 and 146, even if the underlying sale or income happened last year. Bank staff will call them “15CA/CB” for a while yet. Just make sure what gets filed is the new form.

Do you actually need the CA certificate?

Not always. The rule works on the aggregate amount and whether the money is taxable in India.

• Remittance is not taxable in India at all (for example, you are moving your own after-tax NRO balance and no further tax arises): you file the declaration part of Form 145 meant for non-taxable remittances. In practice, banks very often still ask for a CA certificate here, because they want a professional to confirm why it is not taxable. Expect to provide one.
• Taxable remittances totalling ₹5 lakh or less in the financial year: the simple declaration part of Form 145 only. No Form 146.
• Taxable remittances above ₹5 lakh in the financial year (aggregate, not per transaction): Form 146 from a chartered accountant first, then the corresponding part of Form 145.
• You hold a lower or nil TDS certificate from the Assessing Officer (now applied for in Form 128, formerly Form 13): a separate part of Form 145 that references the certificate.

The ₹5 lakh test is cumulative across the year. The most common filing error we see is someone using the “small remittance” declaration in September without noticing they already crossed ₹5 lakh in May.

The sequence that works

1. Assemble the source-of-funds story. For every rupee in the NRO account you want to move, be able to show where it came from: rent agreements and bank credits, FD advices, sale deed and buyer’s TDS certificate, will or legal-heir documents for inherited money, dividend statements.
2. Confirm tax has been dealt with on each stream. Interest: TDS by the bank, visible in Form 26AS and your AIS. Rent: TDS by the tenant or advance tax paid by you, and the income declared in your return. Sale proceeds: capital gains tax paid, or buyer’s TDS plus a filed return. This is where a CA earns the fee, because the certificate is only as good as the compliance behind it.
3. Chartered accountant issues Form 146 and uploads it on the portal with a UDIN. You get the acknowledgement number.
4. File Form 145 on the e-filing portal (you can do it yourself, or your CA can as your authorised representative). One Form 145 per remittance.
5. Submit the bank’s set: the request letter or cheque, the FEMA declaration, the outward remittance form (Form A2), KYC, and the two acknowledgements. Some banks have an NRI desk that pre-checks the file; use it.
6. The bank verifies and remits. With a complete file, most banks process in two to five working days.
7. Keep everything. Forms 145 and 146 are on record with the department, and remittance data is now matched against your return. A remittance that does not reconcile with your filed income is exactly the kind of mismatch that triggers a notice two years later.

Documents you will be asked for

• PAN (and make sure it reflects your non-resident status with the department; PANs recorded as resident and not linked to Aadhaar become inoperative, and an inoperative PAN stalls both refunds and remittances)
• Passport, visa or OCI/residence permit, overseas address proof
• NRO account statements covering the period the funds accumulated
• Source documents for each stream (see step 1)
• Form 26AS / AIS for the relevant years, TDS certificates, tax payment challans
• Income-tax return acknowledgements for the years in which the income was earned
• For inheritance: death certificate, will and probate, or legal-heir/succession certificate, and the bank’s transmission letter
• For property sales: sale deed, buyer’s TDS certificate, capital gains computation, any lower-deduction certificate

Eight reasons banks say no (and what fixes each)

1. Amounts do not match between Form 145, Form 146 and the request letter. Fix: file everything from one worksheet, in rupees, to the paisa.
2. The wrong part of Form 145 was filed for the amount or the nature of the remittance. Fix: check the cumulative total for the year before choosing.
3. Form 146 without a valid UDIN, or issued by someone who is not a practising CA. Fix: the certificate must be generated and uploaded through the CA’s portal login.
4. Filed after the remittance. Both forms are pre-remittance documents; a bank cannot process against a form dated after the transfer. Fix: forms first, request second.
5. The money came from a resident savings account that was never converted to NRO when you left India. Banks treat unconverted resident accounts as a FEMA problem and freeze the request. Fix: regularise the account status first, then remit.
6. Returns were never filed for the years the income was earned. Five years of rent credited to NRO with no returns is the most common surprise at the remittance stage. A CA cannot certify tax compliance that does not exist. Fix: file the returns (belated or updated, depending on the year), pay the tax and interest, then certify.
7. Source of funds has gaps: cash deposits, unexplained credits from friends, or money that arrived from another relative’s account. Fix: document each credit; where it was a gift, get a gift deed and show the donor’s relationship.
8. The USD 1 million limit is already used, often because another bank processed an NRO-to-NRE transfer earlier in the year. Fix: stagger across financial years, and keep one bank as the authorised dealer.

A file from earlier this year

Meera, Toronto (details changed). Her NRO balance was ₹85 lakh: about ₹40 lakh from matured fixed deposits, ₹30 lakh of rent accumulated over five years from a flat in Goregaon, and ₹15 lakh from a mutual fund redemption. She wanted all of it in Canada.

The deposits were straightforward: the bank had deducted TDS on the interest every year, and 26AS showed it. The mutual fund redemption had TDS deducted by the fund house on the capital gains. The rent was the problem. The tenant had never deducted TDS, and Meera had never filed an Indian return, assuming that because the money stayed in India it was somebody else’s concern.

Before any certificate could be issued, three years of returns were filed as belated or updated returns, tax and interest were paid on the rental income, and the position was reconciled with her AIS. Only then was Form 146 issued, Form 145 filed, and the bank’s set submitted. The transfer to her Canadian account cleared in four working days. Total time from first call to funds landing: about seven weeks, five of which were spent fixing the past.

That is the pattern. The remittance itself is fast. The compliance behind it is where the time goes, and it is far better to discover the gaps on your own timetable than when a buyer or a mortgage lender is waiting.

Special situations, briefly

Property sale proceeds. The buyer deducts TDS on the entire sale price unless you obtained a lower-deduction certificate (Form 128) in advance. The proceeds land in NRO, and repatriation follows the route above, with the sale deed and TDS certificate as source documents. If the property was originally bought with NRE or FCNR money, the original investment amount can be repatriated through a simpler route for up to two residential properties; the gain still goes through NRO. Our guide to TDS on NRI property sales covers the certificate step in detail.

Inherited money and assets. Inheritance is not taxed in India, and inherited funds can be remitted within the USD 1 million limit, but banks want the death certificate, will/probate or legal-heir certificate, and the transmission trail. See our separate article on inherited property and money.

NRE to NRO. Any amount, no forms. But it is effectively a one-way door: interest on the money becomes taxable, and bringing it back to NRE later means the full process and a bite out of that year’s limit.

Gifts to relatives abroad. Sending money from NRO to a family member overseas is still a remittance from your account; the same forms apply, plus a gift declaration.

Frequently asked questions

Can I file Form 145 myself? Yes, on the e-filing portal, once Form 146 (where required) has been uploaded by your CA. Many NRIs prefer the CA to file both as their authorised representative so the numbers tie out.

Is there a penalty for not filing these forms? Yes. The law provides for a penalty of up to ₹1 lakh for a missing or incorrect declaration, and the bank will not process the remittance regardless.

Do I need Form 146 to move money from NRO to NRE? For aggregate taxable transfers above ₹5 lakh in the year, yes. Below that, the declaration alone is enough by law, though many banks ask for a certificate anyway.

Can I repatriate rent every month? Yes. Each remittance needs its own Form 145, but a single Form 146 can cover a stated period or a stated set of remittances, depending on your bank’s practice. Many landlords batch quarterly to reduce paperwork.

My old Form 15CB was issued in March 2026 but the bank only processed the transfer in April. Is it valid? The form must match the remittance date. A transfer made on or after 1 April 2026 needs Forms 145 and 146. Ask your CA to reissue.