TITLE: India's Reserve Bank Issues Third Amendment Directions on Non-Banking Financial Company Recovery Conduct
BODY:
On August 6, 2026, the Reserve Bank of India (RBI) issued the Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Third Amendment Directions, 2026, establishing comprehensive instructions governing loan recovery practices and recovery agency engagement by non-banking financial companies (NBFCs).
The amendment modifies the RBI's 2025 Responsible Business Conduct Directions and introduces detailed requirements for NBFCs' recovery operations, excluding Mortgage Guarantee Companies, Core Investment Companies, NBFC-Account Aggregators, Standalone Primary Dealers, Non-Operating Financial Holding Companies, and NBFCs without customer interface. Key provisions include mandatory policies on collection and recovery of loan dues; due diligence and training requirements for recovery agencies; and restrictions on harsh recovery practices including abusive language, excessive contact, intimidation, and misuse of social media. The directions establish that recovery agents must obtain certification from the Indian Institute of Banking and Finance (IIBF) within one year of the effective date.
The amendment introduces specific restrictions on technology-based device-locking mechanisms, permitting NBFCs to restrict mobile device functionalities only for loans financing those devices. Restrictions must follow a gradual approach, cannot disable essential features such as emergency calls, and must be reversed within one hour of payment. Wrongful restrictions trigger compensation of ₹250 per hour, capped at the loan amount. NBFCs must maintain call recordings for six months, disclose recovery agency details to borrowers at least one day before visits, and establish dedicated grievance redressal mechanisms. Contact with borrowers is restricted to 08:00 to 19:00 hours unless expressly authorised otherwise.
The directions come into effect on January 1, 2027, and apply to all applicable NBFCs engaging in recovery activities from borrowers in default.