What changed
RBI observed that many RTGS participants were pushing customer transactions into the inter-bank session after the customer window closed, likely to accommodate late high-value payments. The circular reiterates that different time windows exist for customer and inter-bank transactions, with a 90-minute gap to allow returns. Routing customer payments in the inter-bank mode breaks this discipline and is now explicitly prohibited.
What it means for you
Banks must strictly adhere to RTGS procedural guidelines and stop using the inter-bank window for customer transactions. Non-compliance will be viewed seriously and may lead to penalties under Section 30 of the Payment and Settlement Systems Act, 2007. This ensures timely return of uncredited customer payments and maintains system integrity.
What you must do
- Immediately cease routing any customer RTGS payments through the inter-bank window after the customer window closes.
- Review and reinforce RTGS operational procedures to ensure strict adherence to prescribed time windows for customer and inter-bank transactions.
- Train RTGS operations staff on the 90-minute return discipline and the prohibition on mixing transaction types.
- Monitor transaction logs to detect and correct any instances of customer payments being processed in the inter-bank session.
Who it affects
All banks participating in RTGS, RTGS operations teams, Treasury and payment system departments, Compliance and risk management functions
Why can't we route customer payments through the inter-bank window if it helps high-value clients?
The inter-bank window has a different return discipline—customer payments processed there miss the mandatory 90-minute return window, violating procedural guidelines. RBI views this as a serious breach that can attract penalties.
What is the penalty for violating this circular?
RBI has warned that violations will be viewed seriously and may attract penalty under Section 30 of the Payment and Settlement Systems Act, 2007. The exact penalty amount is not specified in this circular.
Does this circular affect all RTGS transactions or only customer payments?
It specifically targets customer transactions being routed through the inter-bank window. Inter-bank transactions in their designated window remain unaffected.