Banking, lending and collections

Financial companies in India make more customer calls than almost anyone else: EMI reminders, collections, KYC, policy verification and trade confirmations. The Reserve Bank of India (RBI), SEBI and IRDAI each set their own rules for those calls, and the largest change for lenders starts on 1 January 2027.

Lenders should start with RBI's recovery agent rules for 2027, also available in Hindi. From that date, lenders and their recovery agents may call or visit borrowers only between 08:00 and 19:00, must record every recovery call and keep it for six months, and may discuss the debt only with the borrower or guarantor. The directions do not mention AI calls, so the safe course is to hold a bot to the same standard as a person.

Two more RBI rulebooks govern the vendor that places the calls. Under the outsourcing directions, an AI voice vendor that records calls or holds customer data is usually material outsourcing, which brings due diligence, a vetted contract and a six-hour cyber-incident clock, while the lender stays responsible for what the vendor does. The digital lending rules, now a chapter in each lender type's Credit Facilities Directions, make the lender fully liable for its lending service providers and require borrowers to be told who the recovery agent is before the agent makes contact.

Brokers and insurers have their own rules. SEBI's call recording rule and CSCRF require stock brokers to record orders taken by phone, keep them for at least three years and answer for the vendors that record or transcribe those calls. The pre-issuance verification call is no longer required by name, but IRDAI's September 2026 penalty on Canara HSBC Life shows the call is still expected.

Two guides in other topics apply here too: call recording retention compares each regulator's period, and the 1600 number series explains which numbers financial firms must call from.