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Directions · Reserve Bank of India

Reserve Bank of India (Small Finance Banks – Concurrent Audit) Directions, 2026

UR

The four dates on this rule

At a glanceAreas the bank itself marks as risk sensitive must be covered. These Directions apply to small finance banks. These Directions came into effect immediately upon issuance.

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

1. In force at once

RBI Para 1 · Stated by RBI

These Directions came into effect immediately upon issuance.

2. Who is covered

RBI Para 3 · Stated by RBI

These Directions apply to small finance banks.

Chapter II. Governance and Oversight

1. The committee approves scope

RBI Para 6 · Stated by RBI

The board's audit committee must approve the detailed scope of the concurrent audit.

2. A yearly effectiveness review

RBI Para 8 · Stated by RBI

Once a year the committee must review how well the audit system and the auditors work.

3. Tenure and pay upstairs

RBI Para 7 · Stated by RBI

The audit committee fixes external auditors' maximum tenure and their pay.

Chapter III. Guidelines for Concurrent Audit

Must know

1. Risk areas never skipped

RBI Para 10 · Our reading

Areas the bank itself marks as risk sensitive must be covered.

2. Five years with the bank

RBI Para 18(1) · Stated by RBI

An outside auditor may serve the bank at most five years in a row.

3. Three years per branch

RBI Para 18(2) · Stated by RBI

No auditor stays with one branch or unit beyond three years.

BankPulse example. A concurrent auditor may stay with one branch for three years, and no longer. An auditor who starts in April 2024 moves on by April 2027. A retired staff member engaged as a concurrent auditor may not be over 70.

Do it

4. Random tests, large samples

RBI Para 10 · Stated by RBI

Coverage must include random testing of a large enough sample of transactions.

5. Own staff must qualify

RBI Para 15 · Our reading

In house auditors must be experienced, trained, senior and independent of the unit they audit.

6. Accountability for own staff

RBI Para 17 · Our reading

A policy must fix accountability when the bank's own or retired staff slip seriously.

7. Pay matches the work

RBI Para 19 · Needs judgement

Pay must match the audit's scope, the skills, the staff and the time it needs.

8. Follow-up is priority

RBI Para 25 · Stated by RBI

Head office must treat follow-up and rectification of audit findings as high priority.

Background

9. Audit head sets work

RBI Para 9 · Our reading

The internal audit head decides what work goes to the auditors, with the committee's prior approval.

10. Cash counted physically

RBI Para 11(1) · Our reading

Cash work is covered, including physically counting the cash.

11. Loans checked to end use

RBI Para 11(2) · Stated by RBI

Loan work is covered end to end: securities, sanction powers, end use of funds and excess drawings.

12. KYC checks in scope

RBI Para 11(3) · Stated by RBI

The audit covers KYC and anti money laundering work, including suspicious transaction reporting.

13. SWIFT messages watched

RBI Para 11(4) · Stated by RBI

Remittances and bills are covered, including SWIFT messages and overdue purchased bills.

14. Housekeeping and ledgers

RBI Para 11(5) · Stated by RBI

Housekeeping is covered: account reconciliation, control ledgers and internal account openings.

15. Treasury and foreign exchange

RBI Para 11(6) · Stated by RBI

Treasury, non fund based business and foreign exchange all fall inside the audit.

16. Cards and mis-selling

RBI Para 11(11) · Stated by RBI

Card business, employee conduct and product mis-selling are audited.

17. Processing centres covered

RBI Para 12 · Stated by RBI

Every centralised processing centre, including those originating business, is covered.

18. A board approved policy

RBI Para 13 · Needs judgement · Being re-read. RBI's new text no longer matches this line exactly.

A board approved policy says whether the bank's own staff or outside auditors do the work.

19. Audit head picks auditors

RBI Para 14 · Stated by RBI

When the work is outsourced, the internal audit head helps select the auditors and reviews their quality.

20. No board partner conflict

RBI Para 14 · Stated by RBI

If a firm's partner sits on the bank's board, no partner of that firm may be its concurrent auditor.

21. A hearing before action

RBI Para 16 · Our reading

An external firm accused of serious lapses gets a hearing before any adverse action.

22. Proven lapses reported up

RBI Para 16 · Our reading

A proven lapse means cancellation and a report to the committee, RBI and the accountants' institute.

23. Retired staff up to seventy

RBI Para 18(3) · Stated by RBI

Retired staff may work as concurrent auditors only up to age 70.

24. A structured reporting line

RBI Para 21 · Stated by RBI

Findings arrive in a structured format the bank prescribes, under a committee approved reporting system.

25. Small fixes on the spot

RBI Para 22 · Our reading

Small irregularities are fixed on the spot; major ones go straight to head office.

26. A quarterly review upstairs

RBI Para 23 · Our reading

Every quarter the committee sees a review of what the audits found, zone by zone.

27. Fraud goes up at once

RBI Para 24 · Stated by RBI

Detected fraud is reported at once to internal audit and the chief vigilance officer.

Chapter IV. Repeal and Other Provisions

1. Old guidance repealed

RBI Para 26 · Stated by RBI

The earlier concurrent audit circulars for this kind of bank stand repealed.

2. Old actions stay governed

RBI Para 27 · 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 small finance banks

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