An Agentic BPO is a BPO where AI handles calls and people step in when their judgement matters. That operating model also creates an opportunity to make compliance evidence part of the calling process, rather than a report assembled after an inspection request.
The RBI’s 2026 directions on recovery-agent conduct require commercial banks to keep recovery contact within 8 a.m.–7 p.m., unless a borrower or guarantor expressly requests or authorises contact outside those hours. They also require calls to be recorded and records preserved for six months, or until disposal in cases that are sub judice. The directions take effect on 1 January 2027. Collections teams need a dialler rule, a recording-retention process and an audit trail that work together before that date.
What exactly changed, and when does it take effect?
On 6 August 2026, the Reserve Bank of India issued amendments covering recovery conduct across several categories of regulated entities.
For commercial banks, the relevant instrument is the Reserve Bank of India (Commercial Banks – Responsible Business Conduct) Fourth Amendment Directions, 2026. It takes effect on 1 January 2027. The RBI issued separate instruments for other categories, including small finance banks, regional rural banks, cooperative banks, NBFCs and housing finance companies. The amendment number and title therefore depend on the type of regulated entity.
The directions establish requirements for the conduct of recovery operations, including how employees and recovery agents interact with borrowers, the controls lenders must maintain and the records needed to support oversight.
For a collections floor, the implementation work is practical. Dialler schedules need to enforce the permitted window. Exceptions need to be captured against the relevant borrower. Call recordings need to remain retrievable. Reporting must show what actually happened across calls, rather than relying on a policy document or a small quality-assurance sample.
Five months can sound generous. It becomes a tighter deadline when the changes span technology, operations, training and compliance reporting.
Does the calling window apply to every kind of contact?
The commercial-bank directions state that an employee or recovery agent shall contact or visit a borrower or guarantor only between 08:00 and 19:00 hours.
Contact or visits earlier or later are permitted only when the borrower or guarantor has expressly requested or authorised them. The directions also say that requests to avoid contact at a particular time should be honoured in normal circumstances.
That distinction matters. A system that simply blocks every call outside the default window may prevent unauthorised contact, but it also needs a controlled way to handle a valid exception. A system that lets supervisors override the window without recording why creates a different problem.
Consider a borrower who asks to be contacted after a particular work shift. The operational sequence should be clear:
- Capture the request. Record the agreed time or exception against the correct borrower.
- Apply the rule. The dialler checks the borrower’s contact preferences before scheduling the call.
- Enforce the outcome. The system suppresses or reschedules a call that falls outside the permitted window unless a valid exception applies.
- Retain the evidence. The request, applicable rule and resulting call record remain available for review.
This is an example of how to operationalise the requirement, not a claim that the RBI prescribes a particular software design.
The same principle applies when a borrower asks not to be contacted during a particular period. That request should not live only in an agent’s memory or a note that never reaches the dialler. It needs to affect what the system actually does.
The distinction between a rule and an override is important, too. A general preference or an undocumented supervisor instruction should not be treated as equivalent to the express request or authorisation specified by the directions.
What has to exist on file to prove compliance?
“We call within the window” is an assertion. A timestamped record that can be checked against the applicable rule is evidence.
For commercial banks, the directions require the bank to document the time and number of calls made by its employee or recovery agent to the borrower or guarantor. They also require recording of the content or text of calls made by the employee or agent to the borrower or guarantor, as well as calls made by the borrower or guarantor to the telephone or mobile number conveyed by the bank.
The record must be preserved for six months from the date of the call or, where a case is sub judice, until the case is disposed of. The directions also require reasonable precautions, such as informing the borrower or guarantor that the conversation is being recorded.
This creates three separate operational questions:
- Did the call happen within the permitted window? The system needs reliable timestamps.
- Was an exception applicable? The supporting request or authorisation needs to be retrievable.
- Can the evidence still be produced? The recording and associated records must remain available for the applicable retention period.
Recording a call without a retention process does not solve the third problem. Nor does retaining audio alone necessarily answer questions about call timing, frequency or the exception that allowed a particular contact.
A useful compliance report should bring these records together so a reviewer can move from the rule to the individual call and the supporting evidence without reconstructing the sequence from separate systems.
How does this interact with TRAI’s rules on the same calls?
The Reserve Bank governs conduct in loan recovery. The Telecom Regulatory Authority of India governs the telecom framework through which commercial communications are made. For an automated collections operation, both sets of requirements can matter.
TRAI’s Telecom Commercial Communications Customer Preference (Third Amendment) Regulations, 2026, published on 18 September 2026, introduce a framework for Application-to-Person (A2P) calls. These are voice calls initiated by an application, software system or automated platform without direct human dialling, including autodialling, robocalls and prerecorded or artificial-voice calls.
Entities using A2P calls must declare that use to their originating telecom service provider and provide the calling-line identifiers they intend to use. Undeclared A2P calls are treated as unsolicited commercial communication.
The amendment also tightens complaint-based enforcement. Action can be triggered when there are three or more unique complaints within ten days and the sender’s calling-line identifier has also been flagged by the telecom provider’s AI/ML system as suspected unsolicited commercial communication. The framework provides for measures including KYC re-verification, physical verification, outgoing-service barring and, in repeated cases, disconnection. It does not establish an automatic 15-day outgoing-service bar for every first violation.
Numbering-series requirements need a separate distinction. TRAI’s September 2026 amendment identifies the 140xx, 1600xx and 1601xx series in its framework and protects these designated series from blanket spam tagging by call-management applications. The specific 1600-series requirement for certain regulated service and transactional calls arises from separate directions, including a December 2025 direction for IRDAI-regulated entities. It should not be presented as a new, universal BFSI requirement created by the September 2026 amendment.
For a collections floor, the takeaway is straightforward: the RBI calling-window control and the telecom calling framework are different controls, but they can apply to the same outbound call. The dialler needs to know when contact is permitted, how the call is being originated, and whether the calling mode and number configuration meet the applicable requirements.
What should a collections floor change before 1 January 2027?
Four things need attention.
- Check the calling configuration. Confirm the number series and calling mode used by the operation, and establish which TRAI requirements apply to the entity and the type of call. For A2P calls, verify that the required declarations have been made to the telecom provider.
- Put the calling window into the dialler. Configure the 8 a.m.–7 p.m. default for the relevant recovery operation. Add a structured field for an expressly requested or authorised exception, with appropriate controls over who can create or change it.
- Test the recording-retention pipeline. Check that recordings and related records can be retrieved for the required period. Test the process end to end, including what happens when a case is sub judice.
- Build the audit report. The report should connect call timestamps, call counts, recordings and relevant exceptions. Test it against real call records, including calls that were suppressed, rescheduled or made under an authorised exception.
The test should not stop at a successful configuration screen. Run sample scenarios through the full process: a call scheduled inside the window, a call scheduled outside it, a borrower-requested time restriction and an authorised exception. Then check whether the resulting records explain what happened.
That is how a compliance rule becomes an operational control.
Where does “every call scored” actually help here?
A floor that samples 1–2% of calls for quality assurance is also sampling its compliance evidence. It can show a reviewer what happened on the calls it checked, but the sample alone cannot establish what happened across the remaining calls.
A system that logs every call, records its timing and evaluates it against a consistent rule set can make that evidence easier to retrieve. It can also help surface exceptions and calls that need further review.
That does not mean every-call scoring, by itself, guarantees compliance. The underlying rules must be correct, the recordings must be retained, and the reporting must reflect the requirements that apply to the lender. Automation makes the process more observable; it does not replace the need to verify it.
| What needs to be demonstrated | Sampled-QA dialler | Every-call-scored system |
|---|---|---|
| Evidence of calls inside the window | A sample of calls | Timestamped records across calls |
| Borrower-requested time restriction | May depend on manual notes and follow-through | Can be represented as a structured rule |
| Authorised exception | May need manual reconstruction | Can be linked to the relevant call record |
| What an inspection can review | Policy and sampled records | Policy and broader call-level evidence |
| Producing records after the event | May require reconstruction from multiple sources | Easier when records are captured and linked by design |
Key takeaways
- The default window is 8 a.m.–7 p.m. Earlier or later contact requires an express request or authorisation from the borrower or guarantor.
- A borrower’s preferred contact time matters. Requests to avoid a particular time should be honoured in normal circumstances.
- Recording a call is only part of the requirement. The bank must also document call times and counts and preserve the records for the required period.
- The directions take effect on 1 January 2027. That leaves a defined implementation window for dialler configuration, retention and reporting.
- TRAI adds a separate layer for automated commercial calls. A2P calls must be declared to the telecom provider, and complaint-based enforcement has its own conditions. The RBI and TRAI requirements should not be treated as interchangeable.
Frequently asked questions
Does the new calling window apply to NBFCs as well as banks?
The RBI issued separate amendment directions for several categories of regulated entities, including commercial banks, NBFCs and housing finance companies. The applicable instrument and exact requirements should be checked against the entity’s category rather than inferred from the commercial-bank directions alone.
What counts as a borrower-agreed exception?
The commercial-bank directions specify an express request or authorisation for contact or visits outside 8 a.m.–7 p.m. They do not, in the cited provision, prescribe one universal software field or recording format for that request. A lender should retain evidence sufficient to demonstrate that the exception was expressly requested or authorised and applied to the relevant contact.
Does this replace the Fair Practices Code?
The 2026 amendment modifies the existing Responsible Business Conduct Directions. It should not be described as a blanket replacement for every other applicable regulatory obligation. Lenders should review the relevant directions and other requirements that apply to their entity and recovery arrangements.
What happens if a lender keeps calling outside the window?
The cited calling-window provision establishes the conduct requirement, but it does not set out a standalone penalty schedule specifically for each out-of-window call. Lenders should not infer a fixed penalty from this provision alone. The broader regulatory and contractual consequences depend on the applicable requirements and circumstances.
Does declaring an A2P call to the telecom provider make it RBI-compliant?
No. TRAI’s A2P declaration requirement and the RBI’s recovery-conduct requirements address different aspects of the call. A declared A2P call can still breach the applicable recovery calling window or other conduct requirements. Both controls need to be checked independently.
Additional context: NBFC operations.
Check your own dialler before the deadline
Pull your dialler’s calling-window log for last week. Check the timestamps against 8 a.m.–7 p.m. Then inspect the exceptions: can you trace each one to the borrower’s express request or authorisation, and can you retrieve the associated recording and records?
If the answer depends on a supervisor remembering what happened, the control is not yet doing enough.
Start with the log. Find the gaps before an inspection does.
For more on how Oriserve approaches AI-led collections operations, explore our collections solutions and AI agents platform.
Source links: RBI and TRAI primary-document URLs are pending editorial insertion before publication.