RBI recovery agent rules from 1 January 2027: calling hours, call recording and complaints

Why RBI rewrote its recovery agent rules

RBI has regulated how lenders chase overdue loans for years. A circular of 24 April 2008 set rules for how banks use recovery agents, and a circular of 12 August 2022 barred recovery calls before 8 am and after 7 pm for most types of lender. What RBI had not done was give every lender the same detailed rulebook.

When it proposed the new framework, RBI noted that its detailed instructions on recovery agents had been "issued to Scheduled Commercial Banks (excluding Regional Rural Banks) and Housing Finance Companies" only. Duties such as vetting agencies, training agents and holding them to a code of conduct therefore depended on which kind of lender held the loan. After a review announced in its Statement on Developmental and Regulatory Policies of 6 February 2026, RBI decided to issue comprehensive instructions to every regulated lender (RBI press release, 12 February 2026).

The result is nine amendment directions, published on 6 August 2026 and announced together, all taking effect on 1 January 2027 (RBI press release 2026-2027/827). Each adds a section on recovering loans and engaging recovery agencies to that lender's Responsible Business Conduct (RBC) Directions, 2025, which are RBI's rulebooks on how lenders treat customers. The call rules use the same wording in all nine. The housing finance direction simply applies the NBFC text, and otherwise only the lender's name and the paragraph numbers differ.

Two terms run through the text. A recovery agency is any outside firm or person a lender engages to recover dues from a borrower in default, whatever the contract calls it. A recovery agent is the agency's representative who deals with the borrower. The rules also bind the lender's own employees who work on recovery, so moving collections in-house does not take a lender outside them (para C).

Which lenders the directions cover

Because RBI wrote one direction per lender type, the first practical question is which one applies to you. Every main type of RBI-regulated lender is covered except payments banks. They appear in none of the nine directions, and they were not among the lender types in the February 2026 draft either.

Housing finance companies (HFCs) get a short amendment that applies the NBFC (non-banking financial company) paragraphs to them (para 170A). The NBFC direction leaves out mortgage guarantee companies, core investment companies, account aggregators, standalone primary dealers, non-operative financial holding companies and NBFCs with no customer interface. Most of these do not deal with retail borrowers, which is the likely reason they are excluded.

Every direction uses the same paragraph letters, so this guide cites the letter only, such as para Y(4) for the calling window. To find the full reference, put your base number from the table in front of it. Para Y(4) is 100Y(4) for an NBFC, 454Y(4) for a commercial bank and 437Y(4) for a regional rural bank.

When a recovery agent may call or visit

The calling window is the rule lenders will feel first, because it has to be built into every dialler and every field schedule. An employee or recovery agent may contact or visit the borrower or guarantor "only between 08:00 hours and 19:00 hours" (NBFC direction, para Y(4)). The rule covers visits as well as calls, and it applies to every kind of loan.

There is one exception and one limit. Contact outside those hours is allowed only when the borrower or guarantor has expressly asked for it or authorised it. In the other direction, a borrower's request not to be called at a particular time must be honoured in normal circumstances, so a borrower who cannot talk in the evenings can narrow the window further.

The directions do not single out Sundays or public holidays, so calls on those days are allowed within the same window. The text does not settle whether a request to avoid a particular time can cover a whole day, such as every Sunday. Honouring it is the safer course, because refusing would be hard to defend if the borrower later complained.

Timing also depends on what is happening in the borrower's life. Agents must avoid calls and visits during a bereavement in the family, a medical emergency, another calamitous occasion or a marriage function (para Y(6)). Calling outside the window counts as a harsh practice, and so does calling or messaging excessively (para Z(4)). RBI sets no number for excessive, so a lender needs its own written cap per day and per week to show where it drew the line.

What recovery agents may say, and to whom

Once a call connects, the rules turn to who the agent may talk to and how. Loan dues may be discussed only with the borrower or the guarantor (para Y(1)), so an agent may not ring relatives or friends to talk about the loan. Intimidating or harassing the borrower's relatives, referees, friends or co-workers, or intruding on their privacy, is a harsh practice in its own right (para Z(6)).

The directions do not say whether a lender may call a relative only to ask where the borrower is. Any such call risks breaching both paragraphs, so the safer course is to treat it as off limits.

Tone and paperwork are covered as well. Every interaction must be civil and decent (para Y(2)). A letter or written message from an agent needs the lender's prior approval and must carry the sender's name and contact details (para Y(8)). Any payment collected must be acknowledged at once with a proper receipt (para Y(9)).

• Minatory (threatening) or abusive language.
• Posting the borrower's or guarantor's videos, audio recordings or personal details on social media.
• Sending inappropriate messages by phone or social media.
• Calling or messaging excessively, or outside the prescribed hours.
• Threatening or anonymous calls.
• Intimidating, harassing or publicly humiliating the borrower, guarantor or their relatives, referees, friends or co-workers, or intruding on their privacy.
• Using or threatening violence against them, their family, assets or reputation.
• False or misleading statements, especially about the size of the debt or the consequences of not paying.

Recording, call logs and the duties behind each call

The rules on hours and conduct need evidence behind them, and recording supplies it. From 1 January 2027 the lender must make sure every recovery call its employees or agents make to a borrower or guarantor is recorded (para P). The duty runs both ways. Calls the borrower makes to the phone number the lender gave them must be recorded too, so a recovery helpline or callback number is in scope, not just outbound dialling.

The borrower should know about it. The direction asks lenders to take reasonable precautions, such as telling the borrower or guarantor that the conversation is being recorded, which in practice means saying so at the start of the call.

Each recording must be kept for six months from the date of the call. If the case is sub judice, meaning a court case about it is pending, the recording stays until the case is disposed of. The same paragraph requires a log of the time and number of calls, which is the lender's evidence that its calling was not excessive. For how this period sits beside other retention duties, see how long to keep call recordings in India.

For banks, recording is not new. RBI's circular of 24 April 2008 already asked banks to record recovery agents' calls, but it set no retention period, and RBI withdrew it on 28 November 2025. The 2026 rules add the six-month period and extend the duty to every lender type.

How to complain about a recovery agent

For a borrower, the grievance details in every recovery message are the way in. Complain to the lender first, in writing, to the grievance officer named there (para AA), and keep proof of the date, because the next deadline runs from it. A complaint is stronger with the date and time of each call and an early request for the recordings, which the lender has to keep for only six months.

If the lender does not reply within 30 days, or the reply is unsatisfactory, the next step is the Reserve Bank – Integrated Ombudsman Scheme, 2026 (RB-IOS). Where RBI, NPCI (National Payments Corporation of India) or card network rules give the lender longer to reply, that period applies instead. The scheme replaced the 2021 scheme on 1 July 2026. The complaint must be filed within 90 days after the waiting period ends or after the lender's last reply, whichever is later (RBI FAQ, Q17).

Filing is free. The ombudsman can award up to ₹3 lakh for lost time, expenses, harassment or mental anguish, on top of up to ₹30 lakh for consequential loss. Threats or violence can also be reported to the police, which is ordinary criminal law rather than an RBI route. A complaint reaches RBI in these ways:

• Online: cms.rbi.org.in, RBI's complaint portal.
• Email: crpc@rbi.org.in.
• Post: Centralised Receipt and Processing Centre, Reserve Bank of India, Central Vista, Sector 17, Chandigarh 160017.
• Phone help: RBI's contact centre on 14448 gives guidance and complaint status, but it cannot take complaints.

Can an AI voice agent make recovery calls?

RBI has not said. None of the nine directions mentions automated, IVR (interactive voice response) or AI calls. They regulate contact by an employee or recovery agent, and they define a recovery agent as an agency's representative who deals with customers (NBFC para 6(11B)), wording written with people in mind.

Nothing in the text forbids an automated call either. Our reading, which is interpretation and not a rule, is that RBI will judge an automated recovery call by the same duties as a human one. The lender's recovery policy (para D) and its responsibility for recovery conduct do not depend on who or what dials.

Most of the duties translate directly into software settings. On Sonex, for example, each outbound campaign carries its own calling window, time zone and retry limit, and calls are kept as recordings and transcripts. The window and the cap then become configuration rather than reminders to an operator, which is the approach behind AI collections calls for banks and lenders.

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