RBI tightens guardrails against mis-selling by Banks

Regulating Delegated Insurance The New MGA Framework in IFSCs

Brief Overview:

From 1st January, 2027, banks will need to sell smarter and cleaner: the RBI’s new framework raises the bar on consent, suitability, disclosures, agent oversight and digital conduct to curb mis-selling and protect customers.

Technical Details:

Key Highlights

1) No bundling of any third-party product or service (TPPS).

2) Explicit, verifiable customer consent required for sales and marketing.

3) Suitability checks to be based on customer profile and risk factors.

4) Key terms to be disclosed upfront, including fees, risks, lock-ins and penalties.

5) Direct Selling Agent (DSAs) / Direct Marketing Agent (DMAs) and sub-agents subject to tighter oversight, audits and training.

6) Marketing permitted only with consent and Do Not Disturb compliance.

7) Dark patterns prohibited, mandatory dialogue boxes, hidden charges and fake urgency.

8) Digital interfaces to be audited regularly to remove deceptive practices.

9) Mis-selling may trigger refund, cancellation and customer compensation.

Takeaways:

Banks should treat this as a sales-conduct reset, not a disclosure update. Product bundling, customer consent, suitability checks, agent governance and digital journeys will all need a fresh compliance review before the January 2027 effective date.

For further details, please see:

Reserve Bank of India (Commercial Banks – Responsible Business Conduct) Second Amendment Directions, 2026

For any queries/clarifications, please feel free to ping us and we will be happy to chat:

Smrithi Nair & Kshemya Nair

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