RBI Recovery Compliance Checklist for Banks and NBFCs

Effective from 1 January 2027, RBI puts rules around when your agents can call, what they can say, how EMI device locks work, and how complaints are handled. The responsibility for all of it sits with your bank or NBFC, not the agent. Use this checklist to review your current operations against each requirement, spot the gaps, and prioritise what needs fixing before the deadline.

Phone

Who Is This Checklist For?

  1. Compliance & Risk Teams

    Verify your recovery operations against the RBI’s direction before 1 January 2027.

  2. Collections & Recovery Operations

    Check call handling, recording and escalation workflows against the new controls.

  3. Vendor & Agency Management

    Confirm third-party agents meet the certification and data-access standards you're now liable for.

What the Checklist Covers

Call recording and monitoring

What makes a recorded call compliant, not just logged.

Agent and agency governance

Certification, roster and data-access rules for outsourced recovery partners.

Device-lock compliance

Rules and staggered timelines for device-locking software on financed devices.

Grievance redressal

What a compliant escalation path looks like, and when outreach has to pause.

Contact governance

Time windows, blackout periods and frequency caps across every outreach channel.

Call recording and monitoring

What makes a recorded call compliant, not just logged.

Agent and agency governance

Certification, roster and data-access rules for outsourced recovery partners.

Device-lock compliance

Rules and staggered timelines for device-locking software on financed devices.

Grievance redressal

What a compliant escalation path looks like, and when outreach has to pause.

Contact governance

Time windows, blackout periods and frequency caps across every outreach channel.

Call recording and monitoring

What makes a recorded call compliant, not just logged.

Agent and agency governance

Certification, roster and data-access rules for outsourced recovery partners.

Device-lock compliance

Rules and staggered timelines for device-locking software on financed devices.

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