On June 15, 2026, the Reserve Bank of India (RBI) issued a comprehensive set of Amendment Directions targeting Responsible Business Conduct and the Undertaking of Financial Services by Regulated Entities (REs). The objective is to curb mis-selling, regulate Direct Selling Agents (DSAs) / Direct Marketing Agents (DMAs), prohibit “dark patterns” in digital interfaces, and enforce strict compliance in Agency Business and Referral Services.
To provide a structured and actionable overview, the 17 individual notifications (Nos. 13485 to 13501) have been categorized into two primary regulatory pillars:
Part 1: Responsible Business Conduct (Advertising, Marketing & Sale)
This section consolidates 10 Master Directions aimed at standardizing how financial products (including third-party products) are marketed and sold to consumers.
1. Applicable Entities
2. Specific Changes Required
- Regulation of DSAs/DMAs: REs must implement stringent onboarding, monitoring, and accountability mechanisms for Direct Selling and Marketing Agents. REs remain ultimately responsible for the actions of their outsourced agents.
- Prohibition of Dark Patterns: Digital lending apps and banking portals must eliminate deceptive design patterns (e.g., forced continuity, hidden costs, interface interference, disguised advertisements) that trick users into purchasing unwanted financial products.
- Prevention of Mis-selling: Mandatory clear disclosures of risks, terms, and conditions, especially for third-party products. Products must be suitable for the customer’s risk profile.
- Transparent Advertising: Marketing collateral must explicitly distinguish between the RE’s own products and third-party products. Fine print must be clearly legible and easily accessible.
Management Action Plan
- UI/UX Audit (Immediate): Initiate an immediate external audit of all mobile applications and web portals to identify and remove any elements classifiable as “dark patterns” under the new guidelines.
- DSA/DMA Contract Overhaul: Legal and Compliance teams must revise all existing contracts with DSAs/DMAs to include stricter penalty clauses for mis-selling and mandate regular RBI-aligned training.
- Marketing Collateral Review: Establish a rigid approval matrix involving the Chief Compliance Officer (CCO) for all new advertisements, ensuring prominent risk disclosures and clear separation of third-party products.
- Grievance Redressal Enhancement: Set up a dedicated escalation matrix for complaints arising specifically from DSA/DMA interactions or alleged mis-selling.
Part 2: Undertaking of Financial Services (Agency Business & Referral)
This section consolidates 7 Master Directions governing how entities act as corporate agents or provide referral services for third-party financial products (such as insurance, mutual funds, etc.).
1. Applicable Entities
2. Specific Changes Required
- Explicit Consent & Anti-Coercion: REs are strictly prohibited from linking the approval of a core product (e.g., a loan) to the mandatory purchase of a third-party product (e.g., insurance), except where legally mandated. Explicit, opt-in consent is required.
- Conflict of Interest Firewalls: Clear structural and operational separation must be maintained between the core banking/lending business and the agency/referral business to prevent conflict of interest.
- Data Privacy in Referrals: Customer data cannot be shared with third-party financial product providers for referral purposes without explicit, documented consent from the customer.
- Board-Approved Policies: REs must formulate and prominently publish a Board-approved policy on Agency Business and Referral Services, outlining the scope of services, fee structures, and customer protection measures.
Management Action Plan
- Process Decoupling: IT and Operations teams must update Loan Origination Systems (LOS) to ensure third-party products (like credit life insurance) are strictly “opt-in” and not system-mandated for loan progression.
- Consent Architecture Redesign: Revamp digital and physical application forms to capture granular, explicit consent for data sharing with mutual fund or insurance partners.
- Policy Drafting & Board Approval: Draft a comprehensive ‘Agency & Referral Services Policy’ ensuring adherence to the new norms, and schedule it for Board approval by Q3 2026.
- Revenue Stream Assessment: Finance and Strategy teams should assess the potential impact of these stricter opt-in rules on third-party fee income (bancassurance/referral fees) and revise FY27 revenue projections accordingly.
Next Steps: Given the January 1, 2027 implementation deadline, it is recommended to form a Cross-Functional Steering Committee (comprising Legal, Compliance, IT, and Business Heads) by July 2026 to track the successful execution of the aforementioned action plans.