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Directions · Reserve Bank of India

Reserve Bank of India (Urban Co-operative Banks – Managing Risks in Outsourcing) Directions, 2025

UR

The four dates on this rule

At a glanceA bank can never hand off internal audit, compliance checks, KYC decisions or loan sanctioning to an outsider. These Directions apply to every urban co-operative bank. The provider's money and work health must be checked at least once a year.

Official RBI page

What it says

How firm is each point

Stated by RBI — RBI’s own paragraph says this. We have only made it plainer.

Our reading — BankPulse read RBI’s paragraph and shortened it. The paragraph is the authority, not this line.

Needs judgement — RBI leaves this to the bank to settle, so nobody can give you a fixed number here.

Chapter I. Preliminary

Must know

1. Deadline for existing deals

RBI Para 2 · Our reading

Existing IT outsourcing deals must follow these rules by April 10, 2026, or renewal, whichever comes first.

Do it

2. New deals

RBI Para 2 · Our reading

New IT outsourcing deals must follow the rules from the day they are signed.

Background

3. Outsourcing rules for UCBs

RBI Para 1 · Stated by RBI

This document sets the outsourcing rules for urban co-operative banks.

4. Start date

RBI Para 2 · Our reading

These Directions came into effect on the day the Reserve Bank issued them.

5. Who is covered

RBI Para 3 · Stated by RBI

These Directions apply to every urban co-operative bank.

6. Tier-3 and Tier-4 scope

RBI Para 3 · Stated by RBI

IT outsourcing rules under Chapter IV apply only to Tier-3 and Tier-4 UCBs.

7. Services excluded

RBI Para 4(1) · Stated by RBI

Courier, catering, housekeeping, security, and the moving and storing of records are not covered.

8. Material IT outsourcing only

RBI Para 5(1) · Stated by RBI

IT outsourcing rules apply to material IT outsourcing, not a size-based tier.

Chapter II. Role of the Board

1. Board-approved policy

RBI Para 10 · Stated by RBI

The bank's Board must approve the outsourcing policy before outsourcing starts.

Chapter III. Outsourcing of Financial Services

Must know

1. Functions never outsourced

RBI Para 15 · Stated by RBI

A bank can never hand off internal audit, compliance checks, KYC decisions or loan sanctioning to an outsider.

2. Director-owned vendors barred

RBI Para 18 · Stated by RBI

A service provider cannot be owned or controlled by the bank's own director, officer or their relatives.

3. Contract risk named

RBI Para 22 · Our reading

There is a risk that the deal with the provider cannot be enforced.

4. No mixing of records

RBI Para 26 · Our reading

Where a provider serves many firms, records must not be mixed.

5. Breach disclosure

RBI Para 28 · Stated by RBI

Banks must tell RBI immediately about any security breach or data leak.

6. Customer complaint rights

RBI Para 44 · Stated by RBI

Outsourcing never removes a customer's right to complain against the bank.

7. Answer within thirty days

RBI Para 47(3) · Stated by RBI

A complaint must be answered within 30 days at the most, and the procedure must sit on the website.

Do it

8. Control stays at home

RBI Para 17 · Our reading

The lender must keep full control of the work it gives out.

9. Ten risks to weigh

RBI Para 22 · Our reading

Ten named risks must be weighed before work is given out.

10. Guard the customer data

RBI Para 23 · Our reading

Customer data held by the provider must be kept safe.

11. Watch their security

RBI Para 25 · Our reading

The lender must check the provider's safety steps often, and note any breach.

BankPulse example. A bank hires an outside firm to host its records. Signing the contract is not the end of it. The bank must review and monitor that provider's security practices and control processes on a regular basis.

12. Keep our records separable

RBI Para 27 · Our reading

The provider must be able to pick out our records and assets.

13. Lawyer must vet it

RBI Para 29 · Our reading

A lawyer must check the written deal and say it will hold.

14. Agreement must handle risk

RBI Para 29 · Our reading

The deal must name the risks and say how they will be held down.

15. Room to step in

RBI Para 29 · Needs judgement

The deal must leave room to step in to meet the law.

16. Say what the relationship is

RBI Para 29 · Our reading

The deal must say whether the tie is agent and principal, or not.

17. A structure to watch it

RBI Para 31 · Our reading

There must be a team in place to watch and steer the work given out.

18. Central outsourcing record

RBI Para 32 · Stated by RBI

The bank must keep a central record of each material financial-services outsourcing deal. The Board and senior management review it.

19. A yearly financial review

RBI Para 34 · Our reading

The provider's money and work health must be checked at least once a year.

20. Report any slippage

RBI Para 34 · Our reading

The review must bring out any drop in service, secrecy or safety.

21. Reconcile in time

RBI Para 35 · Our reading

Deals with the provider and its helpers must be matched up on time.

22. Test it together

RBI Para 36 · Stated by RBI

The provider must test the plan from time to time, and joint drills may be held.

23. Have a way back

RBI Para 37 · Our reading

The backup plan must look at another provider, or taking the work back.

24. Watch the host country

RBI Para 42 · Our reading

Where a provider is abroad, its country's rule and politics must be watched.

25. Tell the customer

RBI Para 45 · Our reading

Where a customer must deal with a provider, the leaflet must say so.

26. Grievances without delay

RBI Para 47(2) · Our reading

The named officer must see that real customer complaints are put right fast.

Background

27. Hiring former employees

RBI Para 15 · Our reading

Former employees can be hired only if the Audit Committee confirms no in-house expertise exists.

28. Duties do not move out

RBI Para 17 · Our reading

Giving work out does not cut what the lender owes its customers or RBI.

29. Agent conduct liability

RBI Para 17 · Stated by RBI

Banks stay responsible for what their sales agents and recovery agents do.

30. Suspicious reports stay ours

RBI Para 19 · Our reading

Cash and suspicious deal reports stay the lender's own job.

31. Compliance risk named

RBI Para 22 · Our reading

There is a risk that giving work out breaks privacy or other law.

32. Need to know only

RBI Para 24 · Our reading

A provider's staff may see customer data only where the job needs it.

33. Data leak liability

RBI Para 28 · Stated by RBI

If customer data leaks through a vendor, the bank is liable to customers for damage.

34. Half-yearly record review

RBI Para 32 · Our reading

Outsourcing records go for half-yearly review by the Board too.

35. Only confidential jurisdictions

RBI Para 41 · Our reading

Work may go abroad only to a country that upholds secrecy terms.

36. The stricter rule wins

RBI Para 43 · Our reading

Where these rules and the host country's differ, the stricter one wins.

37. Complaint responsibility

RBI Para 46 · Our reading

The bank alone is responsible for fixing complaints about outsourced services.

Chapter IV. Outsourcing of Information Technology (IT) Services

Must know

1. Cyber incident reporting

RBI Para 51 · Stated by RBI

Banks must report a cyber incident to RBI within six hours of the service provider detecting it.

2. Nothing deleted in transition

RBI Para 81 · Our reading

The provider may not wipe or change data while the work is being moved.

Do it

3. Weigh the IT case

RBI Para 50 · Our reading

The case for giving out an IT job must be weighed against its risks.

4. Due diligence each renewal

RBI Para 53 · Our reading

The provider must be checked when hired and again at each renewal.

BankPulse example. A bank's outsourcing arrangement comes up for renewal after three years. Due diligence is done again, not only when it was first signed. The question each time is whether the service provider can still meet the obligations.

5. Look outside as well

RBI Para 55 · Stated by RBI

Outside reviews and market feedback should back up our own checks.

BankPulse example. A bank's own checks on a provider are not the whole picture. It also obtains independent reviews and market feedback on that service provider. Those supplement the findings of its own due diligence.

6. Systems must fit

RBI Para 56 · Our reading

The provider's systems must work with ours, and their service must be good enough.

7. A framework for IT risk

RBI Para 59 · Our reading

A risk plan must cover how IT risks are found, sized and reported.

8. Too much with one provider

RBI Para 61 · Our reading

The lender must weigh the risk of leaning on one provider too much.

9. Put it in writing

RBI Para 67 · Our reading

What each side owes the other must be set out in a written deal that binds.

10. Audit the provider

RBI Para 70 · Our reading

The lender must audit the provider and anyone it hires.

11. An inventory of IT services

RBI Para 76 · Our reading

The lender must keep a list of the IT jobs it has given out.

12. Map the dependency

RBI Para 76 · Our reading

The lender must map how much it leans on outside firms.

13. Plan for each way out

RBI Para 79 · Our reading

The exit plan must cover each way the deal may end, and the time each needs.

14. Name the alternative

RBI Para 80 · Our reading

The exit plan must identify who else could do the work, or whether it comes back in-house.

15. Destroy the data safely

RBI Para 81 · Our reading

The deal must say how data and records are to be wiped or destroyed.

16. Must help the successor

RBI Para 82 · Our reading

The provider is bound to help the next provider hand over smoothly.

17. Announce the ending

RBI Para 83 · Our reading

Where a provider dealt with customers, the end of the deal must be made known.

Background

18. Pooled vendor audits

RBI Para 71 · Our reading

Regulated entities using the same vendor, the co-operative bank included, may share one pooled audit instead of separate ones.

19. Risk sets the audit cycle

RBI Para 72 · Our reading

How often the audit happens turns on the risk and what is at stake.

Chapter V. Repeal and Other Provisions

1. Older rules cancelled

RBI Para 91 · Stated by RBI

This document cancels all older outsourcing rules for urban co-operative banks.

2. Old cases continue

RBI Para 92 · Our reading

Action already taken under the old rules stays governed by them.

The same subject for other kinds of institution

The same subject for other kinds of institution.

Other RBI rules for urban co-operative banks

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