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RBI/2023-24/53 Borrower-friendly · Revenue-restricting Priority: high

Fair Lending Practice – Penal Charges in Loan Accounts

Late-payment penalties become flat 'charges', not extra interest — and can't be compounded
Last updated: 17 Jun 2026, 1:23 am IST

Quick answer

On default, lenders may levy a flat 'penal charge' but not 'penal interest' — and cannot compound it or treat it as a profit line. (RBI/2023-24/53, dated August 18, 2023.) It applies to all commercial banks (incl. sfbs, labs, rrbs; excl. payments banks). Effective: From January 1, 2024 (existing loans: by next review/renewal or within 6 months, whichever is earlier).

Key facts

RBI referenceRBI/2023-24/53 · DoR.MCS.REC.28/01.01.001/2023-24
IssuedAugust 18, 2023
EffectiveFrom January 1, 2024 (existing loans: by next review/renewal or within 6 months, whichever is earlier)
DirectionBorrower-friendly · Revenue-restricting

What changed & why

RBI found that many lenders were using penal interest as a revenue tool rather than a discipline tool. This circular draws a clean line. Any penalty for breaching the material terms of a loan must be a 'penal charge' — a flat amount — and must not be levied as 'penal interest' bolted onto the loan's interest rate. Crucially, penal charges cannot be capitalised: no further interest is computed on the penalty. Normal compounding of the regular interest in the account continues as usual.

Lenders cannot add any new component to the rate of interest to sidestep this. Each RE must adopt a Board-approved policy on penal charges. The amount must be reasonable and proportionate to the breach, and non-discriminatory within a given loan or product category. There is an important consumer protection: for loans to individual borrowers for non-business purposes, penal charges cannot exceed those applied to non-individual borrowers for the same breach.

Transparency is mandatory. The quantum and reason for penal charges must be spelled out in the loan agreement, in the most important terms & conditions / KFS, and displayed on the lender's website under interest rates and service charges. Whenever a reminder for non-compliance is sent, the applicable penal charge must be communicated, as must any actual levy and its reason.

For a LAP or home-loan book, this means EMI-bounce and covenant-breach penalties must be re-papered as charges, removed from the interest computation, and disclosed up front. Credit cards, ECBs, trade credits and structured obligations are outside this circular — they follow their own product directions.

Who this affects

All commercial banks (incl. SFBs, LABs, RRBs; excl. Payments Banks)
All Primary (Urban) Co-operative Banks
All NBFCs including HFCs
All-India Financial Institutions (EXIM, NABARD, NHB, SIDBI, NaBFID)

What you must do

Reclassify all default penalties as flat 'penal charges'; stop levying 'penal interest' on the rate.
Ensure no capitalisation — do not compute further interest on penal charges.
Adopt a Board-approved penal-charges policy that is reasonable and non-discriminatory within each product.
Cap penalties for individual (non-business) borrowers at no more than those for non-individual borrowers.
Disclose quantum and reason in the loan agreement, KFS/MITC and on the website.
Communicate the applicable penal charge in every non-compliance reminder.

Frequently asked questions

Penal interest vs penal charge — what's the difference?

Penal interest is an extra rate added to your loan's interest. A penal charge is a flat fee. RBI now allows only the flat charge, and it cannot be compounded.

Can we still compound the regular interest?

Yes. Normal compounding of the contracted interest continues. Only the penalty itself cannot attract further interest.

Does it cover LAP?

Yes. LAP, home loans and other advances are covered. Only credit cards, ECBs, trade credits and structured obligations are excluded.

Is there a cap on the penalty?

No fixed number, but it must be reasonable, proportionate to the breach, and non-discriminatory. Individual non-business borrowers cannot be charged more than non-individuals for the same breach.

When did existing loans have to comply?

By the next review or renewal date, or within six months of 1 January 2024, whichever is earlier.

How this connects to past RBI circulars

Official source