What changed
RBI inserted new definitions into the 2025 RRB Responsible Business Conduct Directions: compulsory bundling (making one product conditional on another), dark patterns (deceptive UI/UX to mislead users), DSA/DMA sub-agents, explicit consent, and mis-selling (including unsuitable sales, incomplete info, no consent, bundling). These amendments take effect from January 1, 2027.
What it means for you
RRBs must overhaul product sales processes to eliminate forced cross-selling and deceptive digital interfaces. Mis-selling now explicitly covers unsuitable products even with customer consent, and all third-party agents (including sub-agents) face the same compliance burden. Lenders need to update training, consent recording, and system designs before the deadline.
What you must do
- Audit all product bundling practices and remove any compulsory linkage by Jan 1, 2027.
- Review digital platforms (apps, websites) for dark patterns and redesign to ensure transparent user choices.
- Update DSA/DMA contracts to include sub-agent accountability and explicit consent documentation.
- Train sales staff and agents on the new mis-selling definition, especially suitability assessment and consent recording.
- Implement systems to capture and store explicit, informed customer consent for all product sales.
Who it affects
All Regional Rural Banks (RRBs), Direct Selling Agents (DSAs) and Direct Marketing Agents (DMAs), DSA/DMA sub-agents, Business Correspondents (BCs) and Loan Service Providers (LSPs) engaged by RRBs, RRB customers (borrowers, depositors, insurance buyers)
What is 'compulsory bundling' and why is it banned?
Compulsory bundling means forcing a customer to take one product (e.g., insurance) to get another (e.g., a loan). RBI bans it because it restricts customer choice and can lead to mis-selling. From Jan 1, 2027, RRBs cannot make any product conditional on another.
What counts as a 'dark pattern' under these rules?
Dark patterns are deceptive UI/UX designs that trick users into unintended actions, like pre-checked boxes, confusing cancellation flows, or hidden fees. RBI says these amount to misleading ads or unfair trade practices. RRBs must remove such designs from all digital channels.
Do these rules apply to sub-agents of DSAs?
Yes. The amendment defines 'DSA/DMA sub-agent' as any individual engaged by a DSA/DMA to sell or market RRB products. All instructions for DSAs/DMAs also apply to these sub-agents, including consent and mis-selling rules.