What changed
RBI introduced new definitions for compulsory bundling, dark patterns, direct selling agents, explicit consent, and mis-selling in the Payments Banks - Responsible Business Conduct Directions, 2025. These amendments replace earlier instructions on customer appropriateness and suitability, effective from January 1, 2027.
What it means for you
Payments Banks must now ensure no product is sold conditionally with another, avoid deceptive user interfaces, and obtain explicit, documented consent from customers. Mis-selling is clearly defined, covering unsuitable sales, incomplete information, lack of consent, and compulsory bundling, increasing compliance burden and liability for banks.
What you must do
- Review and update all product sales and marketing processes to eliminate compulsory bundling and dark patterns by January 1, 2027.
- Implement systems to capture and document explicit customer consent for every financial product or service sale.
- Train all direct selling agents, sub-agents, and employees on the new definitions of mis-selling and responsible business conduct.
- Audit existing third-party arrangements to ensure compliance with the new DSA/DMA and sub-agent rules.
Who it affects
All Payments Banks (PBs), Direct Selling Agents and Direct Marketing Agents of PBs, DSA/DMA sub-agents, Business Correspondents engaged in sales and marketing
What is considered 'compulsory bundling' under these directions?
Compulsory bundling means making a customer's access to one product or service conditional on also taking another product or service, whether from the bank or a third party. This practice is now explicitly prohibited.
What are 'dark patterns' and how do they affect Payments Banks?
Dark patterns are deceptive user interface or experience designs that trick users into actions they did not intend, like unwanted purchases. Banks must avoid such designs in all digital platforms to prevent misleading customers.
When do these new rules take effect?
The directions come into effect from January 1, 2027, giving Payments Banks time to align their operations and systems with the new requirements.