AKP Banking & Finance Digest November 03, 2025

1. Regulatory Updates

1.1. India

Reserve Bank of India (RBI)

1.1.1. RBI issues draft Guidelines to facilitate faster cross-border inward payments

Reserve Bank of India (“RBI”) published a draft circular on October 29, 2025, to facilitate faster cross-border inward payments, aligned with the Group of Twenty (G20) roadmap and the RBI's Payments Vision 2025. Banks must inform customers immediately on receipt of inward messages. They must reconcile and confirm credits in nostro accounts on a near real time basis or at intervals not exceeding 30 (thirty) minutes. Banks should endeavour to credit inward payments received during foreign exchange market hours on the same business day and those received after market hours on the next business day, subject to the Foreign Exchange Management Act, 1999 (FEMA). Banks may enable straight-through processing for individual residents and provide a digital interface for foreign exchange transactions, including document submission and monitoring. The directions will take effect 6 (six) months from the date of the circular. Comments are invited by November 19, 2025, through RBI's Connect2Regulate portal.

1.1.2. RBI issues Reserve Bank of India (Nomination Facility in Deposit Accounts, Safe Deposit Lockers and Articles kept in Safe Custody with the Banks) Directions, 2025

RBI issued the Reserve Bank of India (Nomination Facility in Deposit Accounts, Safe Deposit Lockers and Articles kept in Safe Custody with the Banks) Directions, 2025, effective November 1, 2025. The Directions align regulatory instructions with amendments made by the Banking Laws (Amendment) Act, 2025 for the Banking Regulation Act, 1949, and apply to all banks. They require banks to offer and administer nomination for deposit accounts, lockers and articles in safe custody, clarify that proprietorship accounts are treated as individual accounts for nomination, allow customers to open accounts without making a nomination, and mandate acknowledgement of registration, cancellation or variation of nomination within 3 (three) working days. Banks must mark “Nomination Registered” and display the nominee's name on passbooks, statements and Term Deposit Receipts (TDR), publicise the facility, and note that prior circulars on nomination stand repealed from the effective date.

Securities and Exchange Board of India (SEBI)

1.1.3. SEBI issues Consultation paper for permitting debt issuers to offer incentives in public issues to certain category of investors

Securities and Exchange Board of India (“SEBI”) issued a consultation to amend the SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021 (NCS Regulations). It proposes a proviso to Regulation 31 to permit issuers to offer a higher coupon or an issue-price discount to defined categories such as senior citizens, women, armed forces personnel and retail subscribers. The incentive would be disclosed upfront and apply only to the initial allottee. SEBI cites weak recent public issuances and notes alignment with equity Offer for Sale (OFS) discount precedents. Comments are due by November 17, 2025.

1.1.4. SEBI issues Consultation paper on comprehensive review of SEBI (Mutual Funds) Regulations, 1996

SEBI released a consultation paper proposing a comprehensive review of the SEBI (Mutual Funds) Regulations, 1996 to simplify language, remove redundancies, and enhance investor protection. Key cost measures include removing the additional 5 (five) basis points (bps) levy charged to schemes, revising expense-ratio slabs, defining total expense ratio (TER) clearly, and excluding statutory levies such as Goods and Services Tax (GST), Securities Transaction Tax (STT), Commodities Transaction Tax (CTT) and stamp duty from expense-ratio limits. Brokerage caps would drop to 2 (two) bps for cash and 1 (one) bps for derivatives, with other execution costs on actuals. Compliance changes include requiring trustees to meet at least 1 (one) time every 3 (three) calendar months with a minimum of 4 (four) meetings a year, shifting investor notices from newspapers to websites, consolidating valuation and investment-limit details in the Master Circular, and clarifying whether specified timelines use calendar, business or working days. Redundant frameworks for Capital Protection Oriented Schemes, Real Estate Mutual Fund schemes and Infrastructure Debt Fund schemes would be deleted or migrated, with existing Infrastructure Debt Funds grandfathered. Public comments are open until November 17, 2025, via SEBI's web portal.

1.1.5. SEBI further extends QSB timeline for T+0 systems implementation

SEBI issued a circular further extending the timeline for Qualified Stock Brokers (QSBs) to implement systems and processes that enable investor participation in the optional T+0 (same day) settlement cycle alongside T+1 (next day). SEBI cited implementation challenges and said it will announce the revised date later, while keeping all other provisions of the December 10, 2024, circular unchanged. Market Infrastructure Institutions (“MIIs”) must take necessary steps, amend byelaws, rules and regulations where required, and inform market participants.

1.1.6. SEBI enables IAs to charge AUA-based fees for second opinions on distributor-held assets

SEBI amended the Master Circular for Investment Advisers to allow Investment Advisers (“IAs”) to charge Assets Under Advice (AUA) based fees when providing a second opinion on assets held under a pre-existing distribution arrangement with another entity. The fee is capped at 2.5 per cent (two point five per cent) of the value of such assets per annum, and IAs must annually disclose and obtain client consent acknowledging that distributor consideration is also payable.

1.1.7. SEBI allows interim certified past-performance sharing by IAs and RAs before PaRRVA launch

SEBI issued a circular providing an interim arrangement that permits IAs and Research Analysts (“RAs”) to share past performance for periods before operationalisation of the Past Risk and Return Verification Agency (“PaRRVA”). Such sharing is allowed only on specific client request, must be one-to-one, must carry a prescribed disclaimer, and the data must be certified by a member of the Institute of Chartered Accountants of India (ICAI) or the Institute of Cost Accountants of India (ICMAI). IAs and RAs that use this facility must enrol with PaRRVA within 3 (three) months of its operationalisation, and after 2 (two) years from operationalisation only PaRRVA-verified risk and return metrics may be communicated. The Investment Adviser Administration and Supervisory Body (IAASB) and the Research Analyst Administration and Supervisory Body (RAASB) must issue communication templates within 1 (one) month, and contraventions may invite summary proceedings under SEBI (Intermediaries) Regulations, 2008. 

1.1.8. SEBI sets rebalancing plan for derivatives on non-benchmark indices

SEBI issued a circular to implement prudential norms for derivatives on Non-Benchmark Indices (“NBIs”), requiring at least 14 (fourteen) constituents, a top constituent weight not above 20 per cent (twenty per cent), a combined top three weight not above 45 per cent (forty-five per cent), and a descending weight structure. SEBI directed stock exchanges to adjust constituents or weights in existing NBIs; compliance will be in a single tranche for BANKEX and FINNIFTY and across 4 (four) monthly tranches for BANKNIFTY to enable orderly rebalancing of Assets Under Management (AUM). Deadlines were extended to December 31, 2025, for BANKEX and FINNIFTY and to March 31, 2026, for BANKNIFTY, with exchanges and clearing corporations required to update byelaws and systems.

1.1.9. SEBI and IEPFA hold “Niveshak Shivir” in Amritsar to clear unpaid dividends and KYC issues

SEBI and the Investor Education and Protection Fund Authority (“IEPFA”) announced the third “Niveshak Shivir” in Amritsar on November 1, 2025, supported by MIIs and Registrar and Transfer Agents (RTAs). The camp will facilitate transfer of unpaid dividends up to 7 (seven) years, assist with Know Your Customer (“KYC”) and nomination updates, and resolve pending IEPFA claims for unclaimed shares and dividends. Participating MIIs include the National Stock Exchange (NSE), BSE Limited (BSE), National Securities Depository Limited (NSDL) and Central Depository Services (India) Limited (CDSL), alongside RTAs such as KFin Technologies and MUFG Intime. Shareholders or authorised representatives should carry government identification, including Voter ID, Permanent Account Number (PAN) card or driving licence.

1.1.10. SEBI issues Consultation paper on Relaxation in the threshold for identification of HVDLEs and measures facilitating ease of doing measures for HVDLE including provisions relating to RPTs

SEBI issued a consultation to raise the High Value Debt Listed Entities (“HVDLEs”) trigger from INR 1,000 crores (Indian Rupees One Thousand Crores only) to INR 5,000 crores (Indian Rupees Five Thousand Crores only), cutting the HVDLE universe from 137 (one hundred thirty-seven) to 48 (forty-eight) entities, a 64 per cent (sixty-four per cent) reduction, and invited comments by November 17, 2025. The paper also proposes alignment of corporate-governance norms in the Listing Obligations and Disclosure Requirements (LODR) Regulations, 2015 with equity-listed rules, including use of “turnover” in the material-subsidiary test, clarified director-age approvals, nominee-director and board-committee vacancy relaxations, “financial year” drafting fixes, secretarial-audit eligibility and tenure rules, and harmonised Related Party Transactions (RPTs).

International Financial Services Centres Authority (IFSCA)

1.1.11. IFSCA amends AML/CFT–KYC Guidelines to expand V-CIP and pilot NRI onboarding

International Financial Services Centres Authority (“IFSCA”) modified the International Financial Services Centres Authority (Anti Money Laundering (AML), Counter-Terrorist Financing (CFT) and KYC) Guidelines, 2022 to allow the Video based Customer Identification Process (“V-CIP”) to be run using infrastructure or authorised officials of a financial-group entity in India supervised by a financial regulator or a KYC Registration Agency (KRA), with stricter controls on encryption, geo-tagged recordings, liveness and anti-deepfake checks, IP-address restrictions and concurrent audit before activation. The circular also launches a pilot permitting low-risk Non-Resident Indian (NRI) customers to be onboarded via V-CIP only from specified jurisdictions, requires debit-freeze until the first credit from the declared overseas bank account, and mandates data-residency safeguards.

1.1.12. IFSCA issues draft Regulatory Framework for Dematerialisation of securities by entities in the IFSC jurisdiction

IFSCA proposed a framework to mandate dematerialisation by entities in the International Financial Services Centre (“IFSC”), requiring issuers to obtain International Securities Identification Numbers (ISINs) from an IFSCA-registered depository rather than domestic depositories and to migrate existing dematerialised securities to an IFSC depository by March 31, 2026. Issuers may still use an International Central Securities Depository (ICSD) for issuance and listing as allowed under the IFSCA (Listing) Regulations, 2024. Depositories in IFSC must ensure seamless migration, provide disclosures, and submit a compliance report by April 30, 2026. Comments on the draft are due by November 16, 2025.

Miscellaneous

Ministry of Corporate Affairs (MCA)

1.1.13. MCA waives additional fees for CRA-4 filings for FY 2024–25

Ministry of Corporate Affairs (“MCA”) issued a General Circular waiving additional fees for Form CRA-4 (Cost Audit Report in Extensible Business Reporting Language (XBRL)) for the Financial Year (FY) ended March 31, 2025, if filed up to December 31, 2025. Filings made after this window will attract applicable fees under the Companies (Registration Offices and Fees) Rules, 2014 from the due date under Companies (Cost Records and Audit) Rules, 2014. The MCA has also indicated that the fee waiver changes for CRA-4 are under development on the MCA-21 Version 3 portal and are expected to be completed shortly, and companies whose due dates have passed or fall during this period should plan filings accordingly.

1.1.14. MCA reshapes company administration with revised RoC jurisdictions and 10 Regional Directors

MCA acted via the Companies Act, 2013 to restructure company administration, effective January 1, 2026. The measures establish specified Registrar of Companies (“RoC”) offices with revised territorial jurisdictions, including 2 (two) in the National Capital Territory (“NCT”) of Delhi, 2 (two) in Uttar Pradesh (Kanpur and NOIDA), 2 (two) in the Mumbai region (Mumbai and Navi Mumbai), 1 (one) at Nagpur, and 2 (two) in Kolkata, with a dedicated RoC for Haryana. They also created 10 (ten) Regional Directors (“RDs”) with headquarters at New Delhi, Chandigarh, Ahmedabad, Mumbai, Navi Mumbai, Chennai, Bengaluru, Kolkata, Guwahati and Hyderabad to discharge functions under the Act, while continuing to exercise powers under the Companies Act, 1956 for provisions still in force.

1.1.15. MCA restructures LLP administration with revised RoC jurisdictions and 10 Regional Directors

MCA acted via the Limited Liability Partnership Act, 2008 to restructure the administration of Limited Liability Partnerships (“LLPs”), effective January 1, 2026. The measures designate specific RoC offices for LLP registration and oversight with revised territorial jurisdictions, including 2 (two) RoC offices in the NCT of Delhi, 2 (two) in Uttar Pradesh (Kanpur and NOIDA), 2 (two) in the Mumbai region (Mumbai and Navi Mumbai), 1 (one) at Nagpur, and 2 (two) in Kolkata covering West Bengal and Sikkim. They also create 10 (ten) RDs with defined headquarters and jurisdictions across New Delhi, Chandigarh, Ahmedabad, Mumbai, Navi Mumbai, Chennai, Bengaluru, Kolkata, Guwahati and Hyderabad to discharge functions under the Act or as delegated by the Central Government.

Unique Identification Authority of India (UIDAI)

1.1.16. UIDAI amends Aadhaar (Payment of Fees for Performance of Authentication) Regulations, 2023

Unique Identification Authority of India (“UIDAI”) notified the Aadhaar (Payment of Fees for Performance of Authentication) Amendment Regulations, 2025 under the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016, coming into force on publication in the Official Gazette. The amendment inputs requiring a requesting entity that has a Memorandum of Understanding (MoU) or agreement with UIDAI to pay the existing fee for each update-response indicating whether a previously submitted Aadhaar number has been omitted, deactivated or re-activated. It exempts the fee where the requesting entity supplies information relevant to deactivation and empowers UIDAI to waive the fee by order where needed for performance of its functions, including maintenance of the Central Identities Data Repository (“CIDR”), continued accuracy of details, processing of information and inquiry into CIDR.

National Payments Corporation of India (NPCI)

1.1.17. NPCI segregates UPI settlement cycles for authorisation and disputes

National Payments Corporation of India (“NPCI”) announced that Unified Payments Interface (UPI) settlements via Real Time Gross Settlement (“RTGS”) will be split so the 10 (ten) existing cycles process authorisation (AUTH) transactions only, while disputes move to 2 (two) dedicated daily dispute cycles labelled DC1 and DC2 that settle at 17:00 and 04:00 respectively. NPCI stated there is no change to cutover timings or RTGS posting for AUTH cycles and directed member banks to update systems, with the revised structure effective November 3, 2025.

Monetary Penalties

1.1.18. RBI imposes penalties on seven banks for regulatory non-compliance

RBI has imposed monetary penalties on the following institutions:

2. Key Asian Markets - Philippines and Vietnam

2.1. Philippines

2.2.1. BSP projects inflation at 1.4 to 2.2 per cent

Bangko Sentral ng Pilipinas (“BSP”) projected October 2025 inflation to settle within 1.4 to 2.2 per cent (one point four to two point two per cent). Upward pressures are from higher priced electricity and from peso depreciation. The BSP said it will monitor domestic and external developments and maintain a data dependent approach to monetary policy.

2.2.2. BSP reiterates market-determined peso and limited foreign exchange intervention

BSP said it allows the peso's exchange rate to be set by market forces and uses foreign exchange (“FX”) operations mainly to dampen inflationary swings over time, not to curb day to day volatility. The BSP noted the recent depreciation may reflect concerns about slower growth tied to the infrastructure spending controversy and expectations of further monetary policy easing by the BSP. It added that resilient remittances, still relatively fast economic growth, low inflation, and structural reforms support the peso, while FX inflows from business process outsourcing, tourism, and overseas Filipino workers help buffer external shocks.

2.3. Indonesia

2.3.1. R&I affirms Indonesia's sovereign rating at BBB+ with stable outlook

Rating and Investment Information, Inc. (R&I) affirmed the Republic of Indonesia's sovereign credit rating at BBB+ with a stable outlook, citing solid macroeconomic fundamentals, favourable demographics, abundant natural resources and a growing manufacturing base. Bank Indonesia (“BI”) noted that inflation remains stable, debt levels are low and monetary and fiscal policies are prudent, while further assessment is required on measures to support growth alongside fiscal consolidation. BI projects 2025 growth around 5 per cent (five per cent), the midpoint of the 4.6–5.4 per cent (four point six to five point four per cent) range; the current account deficit is expected to narrow to about 1 per cent (one per cent) of Gross Domestic Product (“GDP”); and the Government maintains its commitment to keep the fiscal deficit below 3 per cent (three per cent) of GDP.

3. Trends

3.1. FDI Cap in PSU Banks May Rise to 49 per cent

Government of India is discussing with the RBI a plan to lift the foreign direct investment (FDI) ceiling in public sector banks (“PSBs”) to 49 per cent (forty-nine per cent) from 20 per cent (twenty per cent) while retaining at least 51 per cent (fifty-one per cent) state ownership; shares of major PSBs rose about 3 (three) per cent on the chatter, but officials have not confirmed and the contours could change.

3.2. Union Bank of India and Bank of India merger to create mega bank

Ministry of Finance is weighing mergers among public sector banks (PSBs), including a potential Union Bank of India (UBI) and Bank of India (BoI) combination, and exploring later-phase privatisation of Bank of Maharashtra (BoM) and Punjab & Sind Bank; Canara Bank said on October 30, 2025 it has heard “no word from government,” so timelines and choices remain uncertain.

4. Sector Overview

4.1. Fiscal deficit at 36.5 per cent of FY26 target by September

India's fiscal deficit reached 36.5 per cent (thirty-six point five per cent) of the FY26 Budget Estimate during April–September, as per data released on October 31, 2025. The gap reflects elevated capital expenditure alongside softer receipts and remains broadly consistent with the year's fiscal arithmetic that markets track for potential effects on borrowing and bond yields ahead of the Reserve Bank of India (RBI) policy review.

4.2. Rupee holds just above record low as RBI leans on state-bank dollar sales

The Indian rupee finished October 31, 2025 slightly above its all-time low, supported by intermittent dollar selling by state-run banks; separate data showed the Reserve Bank of India (RBI) increased short dollar forwards by USD 6 billion (United States Dollars Six Billion only) in September—the first monthly rise in 6 (six) months—signalling ongoing efforts to manage foreign exchange (FX) volatility that shapes funding costs and hedging for the BFSI sector.

5. Business Updates

5.1. ICICI Prudential enables premium payments via NBBL Banking Connect

ICICI Prudential Life Insurance Company enabled policyholders to pay premiums through NPCI Bharat BillPay Limited (NBBL) “Banking Connect”, allowing in-app payments directly from customers' preferred mobile banking applications without separate internet-banking logins; the insurer said it is the first life insurer to offer this route, underscoring tighter bank–insurer integrations in the BFSI value chain.

5.2. Tech Mahindra–Falcon tie-up to modernise banking technology

Tech Mahindra announced a strategic partnership with Falcon, a cloud-native fintech infrastructure firm, to help banks modernise legacy systems by combining Tech Mahindra's Artificial Intelligence (AI) delivery approach with Falcon's payments and lending stack, including capabilities aligned to Unified Payments Interface (UPI) use-cases, the collaboration targets faster digital transformation programmes at financial institutions.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.