What changed
RBI issued the Second Amendment Directions, 2026 under the Responsible Business Conduct Directions, 2025, effective January 1, 2027. It inserts definitions for compulsory bundling, dark patterns, DSA/DMA sub-agents, explicit consent, and mis-selling into the existing framework. These replace earlier instructions on customer appropriateness and suitability with comprehensive rules on advertising, marketing, and sale of financial products.
What it means for you
Banks must stop forcing customers to buy one product to get another (compulsory bundling) and eliminate deceptive user interface designs (dark patterns) that trick customers. Mis-selling is now explicitly defined as selling unsuitable products even with customer consent, requiring banks to rigorously assess customer profiles. DSA/DMA sub-agents are brought under the same compliance net as primary agents, increasing accountability across the sales chain.
What you must do
- Review all product bundling practices to ensure no compulsory bundling exists; unbundle any conditional product linkages by January 1, 2027.
- Audit all digital platforms (apps, websites) for dark patterns like misleading interfaces or trick options; redesign to ensure clear, honest user experiences.
- Update customer suitability assessment processes to document explicit consent for each product sale, ensuring suitability overrides consent in mis-selling cases.
- Map and register all DSA/DMA sub-agents; ensure they comply with the same training, disclosure, and conduct standards as primary agents.
- Train sales and marketing teams on the new definitions of mis-selling, explicit consent, and dark patterns to avoid regulatory action.
Who it affects
All Commercial Banks (excluding SFBs, Payments Banks, RRBs, Local Area Banks), Direct Selling Agents (DSAs) and Direct Marketing Agents (DMAs), DSA/DMA sub-agents and outsourced sales individuals, Bank compliance and product teams, Digital platform and UX design teams
What is a 'dark pattern' under these new RBI rules?
RBI defines dark pattern as any practice or deceptive design pattern using user interface or user experience interactions on any platform that is designed to mislead or trick users to do something they originally did not intend or want to do, by subverting or impairing the consumer autonomy, decision making or choice, amounting to misleading advertisement or unfair trade practice or violation of consumer rights.