AKP Banking & Finance Digest November 10, 2025

1. Regulatory Updates

1.1. India

1.1.1. RBI flags FATF updates on high-risk and increased-monitoring jurisdictions

Reserve Bank of India ("RBI") summarised outcomes of the Financial Action Task Force ("FATF") Plenary held from October 22, 2025, to October 24, 2025, for Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT). FATF maintains its call for action on the Democratic People's Republic of Korea (DPRK) and Iran. Myanmar remains subject to enhanced due diligence with guidance not to disrupt humanitarian, remittance and legitimate non-profit flows. FATF removed Burkina Faso, Mozambique, Nigeria and South Africa from the "increased monitoring" list and retained other jurisdictions under closer review. Regulated entities are directed to apply countermeasures or enhanced due diligence in line with the updated FATF statements and to consult the linked documents.

1.1.2. World Bank's India FSA flags reform priorities across banking, insurance, markets

RBI noted that the World Bank ("WB") has released India's Financial Sector Assessment ("FSA") under the joint Financial Sector Assessment Program ("FSAP") with the International Monetary Fund ("IMF"), with the IMF's Financial System Stability Assessment ("FSSA") already out; WB posted the FSA on October 30, 2025, and IMF released the FSSA on February 28, 2025. The FSA finds India's system more resilient, diversified, and inclusive than in 2017 and calls for further reforms to mobilise private capital; it welcomes progress but urges stronger credit-risk management in banks and Non-Banking Financial Companies ("NBFCs") via IFRS9 and Pillar-2 add-ons, removal of prudential exemptions for state-owned NBFCs, a shift to risk-based supervision in insurance under the Insurance Regulatory and Development Authority of India (IRDAI), and tighter Securities and Exchange Board of India ("SEBI") market-conduct oversight.

Securities and Exchange Board of India (SEBI)

1.1.3. SEBI issues Consultation paper on Amendments to SEBI (Certification of Associated Persons in the Securities Markets) Regulations, 2007

SEBI has issued a consultation to amend the Certification of Associated Persons in the Securities Markets (CAPSM) Regulations, 2007, proposing to broaden "Associated Person" to include those with intermediaries or regulated entities and those intending to be engaged, directly or indirectly, in the securities market; permit National Institute of Securities Markets (NISM) long-term courses of 3 (three) months or more as an alternative route to certification and Continuing Professional Education ("CPE"); allow CPE in electronic mode; and replace existing exemptions for "Principal", age or experience with a new exemption for individuals aged at least 50 (fifty) years with 10 (ten) years of relevant experience, with age and experience reckoned on the date of the examination or CPE. Public comments are invited until November 27, 2025, via SEBI's web portal.

1.1.4. SEBI issues Consultation on draft circular - Clarifications and specific modalities with respect to maintaining pro-rata rights of investors of AIFs

SEBI issued a draft circular clarifying how Alternative Investment Funds ("AIFs") must maintain investors' pro-rata rights, allowing drawdowns based on either commitment or undrawn commitment with the basis disclosed upfront in the Private Placement Memorandum (PPM), barring reuse of unutilised commitment when an investor is excused or excluded, and linking exposures to the Regulation concentration cap; open-ended Category III AIFs will issue and redeem at Net Asset Value (NAV) and distribute proceeds pro-rata to units (with para-4 conditions if primarily in unlisted securities); existing schemes using other methods must align without treating the change as "material", investors may opt out of further contributions without breaching minimums or corpus-based limits, distributions from pre-December 13, 2024 investments may follow existing waterfalls, "carried interest" sharing with the manager is carved out of the pro-rata distribution requirement, and all commitments are to be recorded in Indian Rupees (INR); the Standard Setting Forum for AIFs (SFA) may issue implementation standards, and public comments are invited until November 28, 2025.

International Financial Services Centres Authority (IFSCA)

1.1.5. IFSCA issues Consultation Paper On The Proposed IFSCA (Pension Fund) Regulations, 2025

IFSCA issued a consultation paper on the proposed International Financial Services Centres Authority (Pension Fund) Regulations, 2025 to enable voluntary pension schemes from an International Financial Services Centre (IFSC) for Non-Resident Indians (NRIs) and foreign citizens. The paper sets out registration and "fit and proper" criteria for Pension Fund Managers (PFMs), including a minimum net worth of USD 1,000,000 (United States Dollars One Million only), staffing and governance standards, daily Net Asset Value (NAV) calculation, and granular disclosures; defines scheme features such as active or auto choice, partial withdrawals, exits via Systematic Withdrawal Plan (SWP) and/or annuity, portability, and an optional healthcare sub-account; and outlines broad investment buckets with geographic diversification. It also records Government of India notifications recognising pension schemes as financial products and exempting Section 25 of the Pension Fund Regulatory and Development Authority (PFRDA) Act, 2013 in the IFSC, and invites public comments.

1.1.6. IFSCA issues Consultation Paper on amendments to the IFSCA (Capital Market Intermediaries) Regulations, 2025

IFSCA issued a consultation to amend the IFSCA (Capital Market Intermediaries ("CMI")) Regulations, 2025. It proposes to add Science, Technology, Engineering and Mathematics (STEM) and fintech postgraduate degrees as valid qualifications for Principal Officer ("PO") and Compliance Officer (CO) roles, and to reduce the experience threshold for graduates to 5 (five) years. Entities holding registrations as broker dealer, clearing member, depository participant, custodian and registered distributor may use one common PO, with a separate distribution vertical head. Liquid net worth would exclude base minimum capital and interest-free deposits with exchanges or clearing corporations but include margins. Custodians would need minimum net worth of USD 1,000,000 (United States Dollars One Million only) and existing entities would have time until January 31, 2026, to comply. IFSCA is also exploring an umbrella registration to allow a single application to cover multiple CMI activities, with comments due by November 24, 2025.

Miscellaneous

Ministry of Corporate Affairs (MCA)

1.1.7. MCA clarifies scope of Section 186 for NBFCs and IFSCA finance companies

Ministry of Corporate Affairs (MCA) notified the Companies (Meetings of Board and its Powers) Amendment Rules, 2025 by substituting rule 11(2) to state that for clause (a) of sub-section (11) of Section 186 of the Companies Act, 2013, the expression "business of financing industrial enterprises" includes, for a Non-Banking Financial Company (NBFC) registered with the RBI, giving any loan or providing guaranty or security for due repayment of any loan availed by any person in the ordinary course of its business, and, for a Finance Company registered with the IFSCA, activities specified in the International Financial Services Centres Authority (Finance Company) Regulations, 2021 in the ordinary course of its business; the amendment takes effect on publication.

Ministry of Electronics and Information Technology (MeitY)

1.1.8. MeitY extends feedback window on draft IT Rules amendments for synthetic content

Ministry of Electronics and Information Technology (MeitY) extended the deadline for stakeholder feedback on draft amendments to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (IT Rules, 2021) concerning synthetically generated information from November 6, 2025, to November 13, 2025. Submissions must be rule wise in Microsoft Word or Portable Document Format (PDF) and emailed to [itrules.consultation@meity.gov.in] and will be held in fiduciary capacity by the Ministry. The draft notification and an explanatory note are available on MeitY's website.

Unique Identification Authority of India (UIDAI)

1.1.9. UIDAI updates Aadhaar (Payment of Fees for Performance of Authentication) Regulations, 2023

Unique Identification Authority of India ("UIDAI") updated the Aadhaar (Payment of Fees for Performance of Authentication) Regulations, 2023, retaining per-transaction fees and inserting a new charge for responses that confirm whether an Aadhaar number was later omitted, deactivated or re-activated. Know Your Customer User Agencies (KUA) pay INR 1 (Indian Rupees One only) for e-KYC responses if they are Telecom Service Providers (TSP) and INR 3 (Indian Rupees Three only) for others; Authentication User Agencies (AUA) and KUAs pay INR 0.50 (Indian Rupees Fifty Paise only) for Yes/No or other non-e-KYC responses. The new status-update response also attracts INR 0.50 (Indian Rupees Fifty Paise only), except where the requesting entity supplies deactivation-relevant information, and UIDAI may waive this by order to support Central Identities Data Repository (CIDR) upkeep.

1.1.10. UIDAI updates Aadhaar (Sharing of Information) Regulations, 2016

UIDAI updated the Aadhaar (Sharing of Information) Regulations, 2016 to tighten consent, child-ID and publication controls. Core biometrics cannot be shared. Demographic data and photographs may be provided to a requesting entity for electronic Know Your Customer (e-KYC) only with the Aadhaar number holder's consent under the Aadhaar (Authentication and Offline Verification) Regulations, 2021, and authentication records must be made available to the holder; disclosures may also occur when required under the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016. For deactivation inquiries under the Aadhaar (Enrolment and Update) Regulations, 2016, UIDAI may use and disclose Central Identities Data Repository (CIDR) data.

1.1.11. UIDAI updates ADV–HSM FAQs on Aadhaar storage, reference keys, and shared-HSM controls

UIDAI updated its Frequently Asked Questions on the Aadhaar Data Vault (ADV) and Hardware Security Module (HSM), mandating that Requesting Entities (REs) store the full Aadhaar number and any connected Aadhaar data from electronic Know Your Customer (e-KYC) responses only in an ADV with an HSM, replace Aadhaar numbers with reference keys across systems, and remove Aadhaar numbers from other databases. It clarifies that Sub-Authentication User Agencies (Sub-AUAs) and Sub-Know Your Customer User Agencies (Sub-KUAs) may use an AUA's/KUA's HSM if logically isolated with dedicated keys, identity-and-access controls, multifactor authentication and robust audit logging, but AUAs/KUAs cannot access a Sub-AUA's/Sub-KUA's ADV.

1.1.12. UIDAI launches 'Aadhaar Vision 2032' review with high-level expert panel

UIDAI announced a strategic and technological review to shape the next decade of Aadhaar through an "Aadhaar Vision 2032 (two thousand thirty-two)" framework, led by an Expert Committee chaired by Neelkanth Mishra, Chairperson, UIDAI. The committee brings leaders from academia, industry and administration to define a next-generation architecture aligned with the Digital Personal Data Protection Act, 2023 (DPDP Act, 2023). The roadmap targets major upgrades to UIDAI's technology stack, leveraging Artificial Intelligence (AI), blockchain, quantum computing, advanced encryption and next-generation data-security mechanisms to improve resilience, scalability and privacy while maintaining public trust.

Monetary Penalties

1.1.13. RBI imposes penalties on four banks for regulatory non-compliance

RBI has imposed monetary penalties on the following institutions:

2. Key Asian Markets - Philippines and Vietnam and Indonesia OR Sri Lanka and Bangladesh

2.1. Philippines

2.2.1. BSP reports asset growth and resilience in Philippine banking

Bangko Sentral ng Pilipinas ("BSP") said banking-sector assets rose 7.7 per cent (seven point seven per cent) year on year to PHP 28.2 trillion (Philippine Pesos Twenty-Eight Trillion Two Hundred Billion only) in June 2025, driven by stable deposits and strong liquidity and capital buffers, with asset quality satisfactory and loans and investments forming the bulk of assets. Profit increased 4.1 per cent (four point one per cent) year on year to PHP 198.1 billion (Philippine Pesos One Hundred Ninety-Eight Billion One Hundred Million only) for the period ended June 2025. The report also notes robust performance of foreign currency deposit units and trust entities, and highlights initiatives on credit information, anti-money laundering and counter-terrorist financing, retirement-savings digitalisation, and a Financial Cyber Resilience Governing Council.

2.2.2. BSP sets Discount Window Facility rates effective November 10, 2025

BSP published Discount Window Facility ("DWF") rates effective November 10, 2025, with peso loans priced at 5.9657 per cent (five point nine six five seven per cent) for 1 (one)–90 (ninety) days and 6.1814 per cent (six point one eight one four per cent) for 91 (ninety-one)–180 (one hundred eighty) days. The United States dollar (US dollar) and Japanese yen (JPY) DWF rates are set for 1 (one)–360 (three hundred sixty) days based on applicable benchmark rates. The BSP noted that peso DWF rates reference the BSP Overnight Lending Rate and that DWF spreads may be adjusted periodically to align with monetary policy objectives and market interest-rate movements.

2.3. Indonesia

2.3.1. Indonesia's foreign reserves rise to USD 149.9 Billion

Bank Indonesia ("BI") reported that official reserve assets at end-October 2025 increased to USD 149.9 billion (United States Dollars 149.9 Billion only) from USD 148.7 billion (United States Dollars 148.7 Billion only) at end-September 2025, aided by government global bond issuance, tax and service receipts, and rupiah-stabilisation measures. BI said reserves equal 6.2 (six point two) months of imports, or 6.0 (six) months of imports plus Government external-debt service, above the international adequacy norm of 3 (three) months. BI judged the level sufficient to support external-sector resilience and macro-financial stability, helped by sustained exports and foreign-investment inflows.

2.3.2. Indonesia maintains trade surplus on resilient non-oil and gas exports

BI reported a September 2025 trade surplus of USD 4.34 billion (United States Dollars 4.34 Billion only), following USD 5.49 billion (United States Dollars 5.49 Billion only) in August 2025, as a non-oil and gas surplus of USD 5.99 billion (United States Dollars 5.99 Billion only) offset an oil and gas deficit of USD 2.68 billion (United States Dollars 2.68 Billion only). BI cited strength in commodities based on natural resources, jewellery and gems, metals and machinery, with China, the United States and India as key markets, and noted a narrower oil and gas deficit on month. BI said the sustained surplus supports external resilience and that it will continue policy coordination with the Government to bolster durable, sustainable growth.

3. Trends

3.1. PSB Mergers and Privatisation Rumours Lift Bank Stocks

Shares of multiple Public Sector Banks (PSBs) rose up to 3 per cent (three per cent) amid fresh media chatter about a new consolidation blueprint, with combinations such as Union Bank of India (UBI) – Bank of India (BoI) and later-phase privatisation possibilities for Punjab & Sind Bank and Bank of Maharashtra (BoM) floated by reporters; no deals are announced, so outcomes and timelines remain uncertain. [

3.2. SEBI May Soften Proposed Cap on MF Brokerage Fees

SEBI is open to raising the proposed ceiling on brokerage fees paid by mutual funds (MFs) after industry pushback; if adopted, this could ease revenue pressure on institutional brokers and reduce frictions for asset managers, but the deliberations are ongoing, and the final framework is uncertain.

4. Sector Overview

4.1. Foreign exchange reserves decline as currency management stays active

Coverage citing RBI data said foreign exchange (FX) reserves fell by USD 5.6 billion (United States Dollars Five Billion Six Hundred Million only) to USD 689.73 billion (United States Dollars Six Hundred Eighty-Nine Billion Seven Hundred Thirty Million only) for the week ended October 31, 2025, reflecting a mix of intervention and valuation effects that influence liquidity, hedging costs, and bond flows watched by BFSI participants.

4.2. Rupee holds near record low as RBI interventions tighten liquidity

The Indian rupee traded in a tight 88.50–88.80 (eighty-eight point five zero to eighty-eight point eight zero) band to the United States dollar as the RBI was seen selling dollars; traders said the defence drained rupee liquidity and pulled one-year forward premiums down to about 2.13 per cent (two point one three per cent), keeping funding conditions and bond-yield expectations in focus for BFSI.

5. Business Updates

5.1. Mahindra & Mahindra exits RBL Bank with full stake sale

Mahindra and Mahindra sold its entire 3.53 (three point five three) per cent stake in RBL Bank for INR 678 crore (Indian Rupees Six Hundred Seventy-Eight Crore only), booking a 62.5 (sixty-two point five) per cent gain on its 2023 investment; the divestment follows Emirates National Bank of Dubai's proposed control deal for RBL Bank and rebalances the automaker's financial-sector exposure.

5.2. SBI and Amundi to offload part of SBI Funds Management via IPO

State Bank of India ("SBI") said it and Amundi will sell a combined 10 (ten) per cent stake in SBI Funds Management through an Initial Public Offering (IPO), with SBI divesting 6.3 (six point three) per cent and Amundi 3.7 (three point seven) per cent; banker appointment and valuation work will precede timelines, and the asset manager's operations continue unchanged.

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.