What changed
RBI operationalized the CRILC system for collecting data on large credits (₹5 crore and above aggregate exposure). Lenders must now submit quarterly CRILC-Main reports (covering exposure, written-off accounts, current account balances, non-cooperative borrowers) and event-based CRILC-SMA 2/JLF reports when a borrower is overdue 61+ days or a JLF is formed.
What it means for you
Banks and term-lending institutions must ensure robust data quality as CRILC data is shared among lenders for early distress recognition. The quarterly deadline (21 days post-quarter) and event-based triggers require tighter internal data aggregation and reporting processes. Non-adherence can lead to penalties under Section 45(L) of RBI Act.
What you must do
- Set up XBRL-based reporting system for CRILC-Main and CRILC-SMA 2/JLF submissions before June 2014 quarter end.
- Ensure borrower-wise data on all exposures ≥₹5 crore (fund-based and non-fund based) is captured accurately.
- Implement internal alerts to trigger CRILC-SMA 2 report within 61 days of overdue and JLF formation.
- Submit quarterly CRILC-Main report within 21 days of quarter close; assign a dedicated team for data quality checks.
- Train staff on penal provisions for non-compliance and establish escalation mechanism for reporting errors.
Who it affects
All India term-lending and refinancing institutions, Banks with large corporate credit portfolios, Credit risk and compliance teams handling CRILC reporting
What is the threshold for reporting to CRILC?
All borrowers with aggregate fund-based and non-fund based exposure of ₹50 million (₹5 crore) and above must be reported.
What are the deadlines for CRILC submissions?
CRILC-Main is due quarterly within 21 days from quarter close. CRILC-SMA 2 and JLF Formation reports must be submitted on an as-and-when basis, i.e., when a borrower is overdue for 61 days or a JLF is formed.
What happens if we fail to report or report incorrect data?
Non-adherence to reporting instructions attracts penal provisions under Section 45(L) of the RBI Act, 1934. Data quality is critical as CRILC data is shared among all reporting entities.