RBI outsourcing guidelines 2025 for AI voice vendors: what banks and NBFCs must check

Why RBI's outsourcing rules reach an AI voice vendor

Outsourcing lets a lender buy skills and scale it does not have, but it moves risk to a firm the regulator does not supervise directly. RBI's answer is to leave the risk where the licence is. The lender stays responsible for what it outsources, including the acts of the sales agents and recovery agents who act for it (paras 9 and 17 of the bank directions).

An AI voice vendor fits that picture closely. It speaks to the lender's customers in the lender's name, and it usually stores recordings, transcripts, phone numbers and account details on its own systems. If it misleads a borrower or leaks data, RBI looks to the lender, so the vendor's contract, security and complaint handling become the lender's own compliance work.

The current rules are the Managing Risks in Outsourcing Directions, 2025, which RBI issued on 28 November 2025 and which came into force immediately (para 2). For commercial banks the instrument is RBI/DOR/2025-26/171, and for NBFCs (non-banking financial companies) it is RBI/DOR/2025-26/363.

Small finance banks, payments banks, local area banks, urban and rural co-operative banks, all-India financial institutions and credit information companies each have their own version of the same date. We found no version for regional rural banks in RBI's Master Directions list (checked 24 October 2026), and the commercial bank directions exclude them (para 3).

Is an AI calling vendor material outsourcing?

Usually, yes. The first question is whether the arrangement is outsourcing at all. Outsourcing means a third party doing, on a continuing basis, work the lender would normally do itself, and an agreement for a limited period still counts (para 6(1)).

Calling borrowers, sending reminders, selling products and answering customer queries are all work a lender would otherwise do, which is the job of AI voice agents for banks and lenders. A short pilot that calls real customers or holds their data is therefore outsourcing too, and should go through the same materiality test and due diligence as a full contract.

• how important the outsourced activity is;
• its effect on earnings, solvency, liquidity, funding, capital and risk profile;
• the harm to the lender's reputation, brand and plans if the vendor fails;
• its cost as a share of total operating costs;
• how much the lender already depends on that vendor; and
• for NBFCs, how much the activity matters for customer service and protection.

Due diligence before signing and every year after

Once a vendor is material, the lender must check it properly before signing and again at renewal (paras 29 to 31). Para 30 lists what to weigh, including the vendor's experience and competence, financial strength, reputation and complaint history, and concentration risk. It also covers the checks the vendor runs on its own staff and subcontractors, and its security, internal controls and business continuity.

IT outsourcing adds more factors (para 66 for banks, para 71 for NBFCs). These include the vendor's technology stability, backups and disaster recovery, its ability to keep the lender's data separate from other clients' data, and its information and cyber security risk.

The checks do not stop at signature. The lender must review every vendor's financial and operational condition at least once a year (para 38), and keep a central record of all material outsourcing, which the board reviews every six months (para 36). The diagram below traces the whole arrangement from the materiality test to exit.

For an AI voice vendor, the factors translate into a handful of plain questions. A fuller set is in the AI voice vendor due-diligence questionnaire, and how to evaluate an AI voice vendor covers the quality side. The questions that map most directly to the directions are:

• Who builds and runs the voice agent, and who are its subcontractors, including AI model providers?
• Where are recordings, transcripts and logs stored, and who can access them?
• How is the lender's data kept separate from other clients' data (paras 26–27)?
• What happens to calls if the vendor's platform or its model provider goes down?
• What audit reports and certifications can the vendor share, and how recent are they?

The contract and the six-hour incident clock

What due diligence finds has to be fixed in the contract, which must be in writing and vetted by the lender's legal counsel (para 33). Para 34 lists the clauses every outsourcing contract needs, and para 69 for banks (para 74 for NBFCs) adds more for IT services.

The clause with the tightest timing is incident reporting. The vendor must report cyber incidents to the lender without undue delay, so that the lender can report them to RBI "within six hours of detection by the service provider" (para 56 for banks, para 61 for NBFCs). The clock starts when the vendor spots the incident, not when it tells the lender, so every hour the vendor waits comes out of the lender's time.

Separately, the lender must notify RBI immediately of any security breach or leak of confidential customer information, and it is liable to its customers for any damage (para 28). In practice the contract should set a vendor reporting deadline well under six hours, for example two hours from detection, with a named contact at each end. For an AI voice vendor, these are the clauses that matter most (bank paragraph numbers):

• Audit: the lender's internal or external auditors can audit the vendor (34(vii), 69(i)).
• RBI access: RBI can access records and inspect the vendor and its subcontractors (34(viii)–(ix), 69(xii), 76).
• Confidentiality: controls on customer data that continue after the contract ends (34(v), 34(xi), 69(xix)).
• Subcontractors: the lender's prior approval before the vendor uses one, with the vendor staying liable for them (4(2), 34(iv), 69(i), 69(xiii)).
• Incidents and data location: which adverse events, such as breaches or outages, the vendor must report (69(iii)), and storage in India where the rules require it (69(vi)).
• Continuity: contingency plans that are tested (34(vi), 69(x)).
• Exit and records: a termination clause with a minimum notice period and an orderly transfer (34(x), 69(xv)), and records kept in line with the lender's legal duties (34(xii)).

Offshore servers, cloud platforms and foreign AI models

Most AI voice platforms run in the cloud, and many use components hosted abroad. The directions allow offshore and cloud vendors, but with conditions. For an offshore vendor, the lender must monitor country risk and fix the governing law (paras 88 to 89 for banks). It must also keep records available even if the vendor is liquidated, and keep RBI's right to audit or inspect the vendor. For financial services, all original records must continue to be kept in India (para 47(viii)).

For cloud services, the lender should contract only with providers in jurisdictions that enforce agreements. It must use multi-factor authentication and least-privilege access, and keep encryption keys and hardware security modules under its own control (para 92). Logs should feed into its security operations centre, and it needs a cloud exit plan that ends with a secure purge of its data (para 92(xvi)).

AI models raise a less obvious version of the same issue. A voice platform that sends audio or transcripts to an AI model provider abroad is sending customer data offshore. Our reading is that the lender should treat that model provider as a subcontractor and have it named in the contract, since the subcontractor clauses (4(2), 34(iv), 69(xiii)) do not distinguish model providers from any other. India's data protection law adds duties of its own, covered in the DPDP Act for voice AI.

Complaints and customers stay with the lender

Whatever the vendor does on a call, the lender handles the customer's complaint about it. Outsourcing does not affect customers' rights against the bank (para 49), and responsibility for complaints about outsourced services rests with the bank (para 51). The NBFC directions say the same (paras 54 and 56).

The response time, at most 30 days, must be on the bank's website. A customer whose complaint is rejected, or not answered within 30 days, can go to the RBI Integrated Ombudsman (para 52(3)). That paragraph still names the 2021 scheme, which the Integrated Ombudsman Scheme, 2026 replaced on 1 July 2026. NBFCs outside the ombudsman scheme send such customers to RBI's Consumer Education and Protection Cell instead (NBFC para 57(4)).

Customers must also know that vendors are involved. Banks must say in product literature that service providers may be used, including for sales and marketing (para 50). If a lender ends a customer-facing vendor's contract, it must publicise the end so customers stop dealing with that vendor (para 44). Banks also tell the Indian Banks' Association, which keeps a caution list; NBFCs display a notice in branches, post it online and inform customers.

For collections vendors, the conduct on each call is set by separate rules. RBI's recovery agent rules from 1 January 2027 cover calling hours, recording and what agents may say. The digital lending rules for lending service providers add disclosure duties for digital loans.

Board oversight, work that cannot be outsourced, and the FREE-AI report

All of this sits under the board. The directions give it specific approval and review duties, and they put some work beyond the reach of any vendor.

Key dates