AKP Banking & Finance Digest July 28, 2025

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1. Regulatory Updates

1.1. India

Reserve Bank of India (RBI)

1.1.1. RBI issues draft Master Direction – Digital Banking Channels Authorisation (Directions), 2025

The Reserve Bank of India (“RBI”) has released the draft Master Direction on ‘Digital Banking Channels Authorisation (Directions), 2025' for public consultation until August 11, 2025. It sets eligibility criteria for banks to offer digital banking services, requires policies on operational risk, cybersecurity, and customer protection, and mandates reporting to concerned regional office of the Reserve Bank for transactional services based on Core Banking Solution (CBS). The Directions also cover compliance, customer consent, transaction limits, and fraud monitoring. Comments can be submitted via RBI's ‘Connect 2 Regulate' portal or email.

1.1.2. RBI restores, cancels and accepts surrender of NBFC's Certificate of Registration

The RBI via multiple press releases dated July 21, 2025, announced significant regulatory actions concerning Non-Banking Financial Companies (“NBFC”) under the applicable provisions of the Reserve Bank of India Act, 1934. The same are as follows:

The Securities and Exchange Board of India (SEBI)

1.1.3. SEBI and MIIS launch Joint Investor Awareness Campaign: SEBI vs SCAM

The Securities Exchange Board of India (“SEBI”), in collaboration with Market Infrastructure Institutions (“MIIs”), including National Stock Exchange (NSE), Bombay Stock Exchange (BSE), Central Depository Services Limited (CDSL), National Securities Depository Limited (NSDL), Multi-Commodity Exchange (MCX), Metropolitan Stock Exchange of India Limited (MSEI), National Commodity and Derivatives Exchange Limited (NCDEX), and the Association of Mutual Funds in India (AMFI), has launched a joint media campaign titled "SEBI vs SCAM". The campaign educates investors on prevalent scams such as fake trading apps, unregistered investment advice from social media and finfluencers, deepfakes, intermediary impersonation, and paid trading courses promising guaranteed returns.

1.1.4. SEBI releases consultation paper for review of LODR Regulations – measures towards Ease of Doing Business

The SEBI consultation paper titled “Review of LODR Regulations - Measures Towards Ease of Doing Business” released on July 25, 2025, focuses on simplifying and rationalising compliance under the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“LODR”). Key proposed changes include easing compliance for issuers of listed non-convertible securities by aligning the requirements for sending annual reports with those for equity shareholders. Instead of sending hard copies of annual reports to debenture holders without registered emails, issuers would send a letter containing a QR code and a web link to access the reports. Additionally, timelines for sending these documents are to be specified, with companies following the Companies Act, 2013 timelines, and other entities adhering to their respective laws or a 21 (twenty-one) day timeline before the annual general meeting. Public feedback is invited by August 15, 2025.

International Financial Services Centres Authority (IFSCA)

1.1.5. IFSCA issues guidelines on ascertaining KMP eligibility under Regulation 7 of the IFSCA (Fund Management) Regulations, 2025

The International Financial Services Centres Authority (“IFSCA”) has released comprehensive guidelines clarifying eligibility under Regulation 7 of IFSCA (Fund Management) Regulations, 2025 and appointment norms for Key Managerial Personnel (“KMP”) within Fund Management Entities (“FMEs”) operating in IFSCs. KMPs must be based in the IFSC, hold relevant professional or postgraduate qualifications, and have a minimum of five years' experience in securities or financial markets roles such as fund management, advisory, or related consultancy (limited to two years). The guidelines detail which types of regulated and unregulated financial sector experience qualify, emphasise on excluding non-core roles and self-managed funds, and encourage FMEs to seek authority confirmation before appointment to ensure compliance and transparency.

1.1.6. IFSCA issues Corrigendum 03 to the RFP for Digital Regulatory Reporting Solution

The IFSCA, on July 21, 2025, has introduced key updates to the selection process of a solution provider for the Digital Regulatory Reporting (“DRR”) project. Bid deadlines are extended to August 11 and 12, 2025, for submission and pre-qualification bid opening, respectively. Financial eligibility criteria are clarified with specific documentation requirements, and Micro Small and Medium Enterprises (“MSMEs”) or startups are exempted from earnest money deposit (“EMD”) submission under certain conditions. The corrigendum refines payment terms, allowing invoicing at both implementation and operations phases, introduces a penalty waiver clause for resource replacement delays under justified circumstances, and updates evaluation scoring with a more detailed turnover-based grading and cloud hosting experience.

Miscellaneous

Telecom Regulatory Authority of India (TRAI)

1.1.7. TRAI leads joint regulators push against spam and cyber fraud

The Telecom Regulatory Authority of India (“TRAI”) has convened a meeting of the Joint Committee of Regulators (“JCoR”), advancing coordinated regulatory action on spam and cyber fraud, with participation from RBI, SEBI, Insurance Regulatory and Development Authority (“IRDAI”), Pension Fund Regulatory and Development Authority (“PFRDA”), Ministry of Electronics and Information Technology (“MeitY”), and National Payments Corporation of India (“NPCI”). The committee agreed to push for adoption of the 1600 (one thousand six hundred) series number for commercial and service calls in the Banking, Financial Services and Insurance (BFSI) sector, aiming to curb misuse and enhance customer identification. A pilot on Digital Consent Acquisition (DCA) was also launched with seven major banks and telecom.

Insurance Regulatory and Development Authority of India (IRDAI)

1.1.8. IRDAI unveils draft guidelines for Internal Insurance Ombudsman to boost policyholder protection

IRDAI has released draft Internal Insurance Ombudsman Guidelines, 2025, for public consultation. The draft mandates insurers, except reinsurers under three years, to have an independent review mechanism for unresolved or escalated complaints. Insurers must appoint internal Ombudsmen to resolve claims up to INR 50 Lakh (Indian Rupees Fifty Lakh only). Multiple ombudsmen may be appointed for wider coverage. The guidelines cover eligibility, tenure, independence, and roles. Public comments are invited by August 17, 2025.

Ministry of Electronics and Information Technology (MeitY)

1.1.9. Expression of Interest for transfer of technology of “Vivan-BCI”

Centre for Development of Advanced Computing (“C-DAC”), under MeitY, has invited Expressions of Interest (“EOI”) for licensing its brain-computer interface assistive technology for individuals with special needs “Vivan–BCI.” The non-invasive system enables non-verbal communication using EEG signals, supports multiple languages, and has been successfully tested at premier institutions. Indian entities, including MSME and start-ups, may apply by August 06, 2025. The license offered is non-exclusive, with C-DAC providing technical support for commercialisation.

1.1.10. CERT-In issues Cyber Security Audit Policy Guidelines for uniform and rigorous assessments

Indian Computer Emergency Response Team (“CERT-In”), under Meity, has released the ‘Comprehensive Cyber Security Audit Policy Guidelines' to standardise and strengthen cybersecurity audit practices. Applicable to CERT-In empanelled auditing organisation and auditee organisations, the document outlines minimum annual audit frequencies, data handling protocols, and mandatory audit scopes—including but not limited to red team assessment, Vulnerability Assessment Penetration Testing, Internet of Things (IOT) and Artificial Intelligence (AI) systems. The guidelines, issued under Section 70B of the IT Act, 2000, are enforceable from July 25, 2025 and are aimed at ensuring a secure Information and Communication Technology system through disciplined and accountable auditing practices.

Monetary Penalties

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

RBI has imposed monetary penalties on banks across Maharashtra and Karnataka for various violations of regulatory guidelines. These enforcement actions were imposed in exercise of powers under Section 47A(1)(c) read with Sections 46(4)(i) and Section 56 of the Banking Regulation Act, 1949, following RBI's statutory inspections.

2. Key Asian Markets- Philippines and Vietnam

2.1. Philippines

2.1.1. BSP launches Tap-to-Pay and QR Code systems at MRT-3 to promote cashless transit

The Bangko Sentral ng Pilipinas (“BSP”) has introduced tap-to-pay and QR code payment options at Metro Rail Transit Line 3 (MRT-3) stations, in collaboration with the Department of Transportation and GCash. This Automated Fare Collection System enables commuters to pay with credit/debit cards or digital wallets, eliminating ticket purchases. The initiative supports the Philippines' cash-lite economy goal and aims for interoperability, security, and reliability. It aligns with the Philippine Development Plan to digitise 60–70 per cent (sixty - seventy per cent) of retail payments by 2028.

2.2. Vietnam

2.2.1. SBV issues developments of interest rates applied by credit institutions

In June 2025, the VND deposit rates were 0.1-0.2 per cent (zero point one - zero point two per cent) for short-term, 6.8-7.1 per cent (six point eight - seven point one per cent) over twenty-four months. USD deposits stayed at 0 per cent (zero per cent). VND lending rates averaged 6.5-8.8 per cent (six point five – eight point eight per cent); USD loans were 4.1-5 per cent (four point one – five per cent).

3. Trends

3.1. UPI and PayPal partnership to enable global payments for Indian users

PayPal has announced a partnership with NPCI International that will soon allow Indian users to make UPI payments on international e-commerce websites. The collaboration is part of the new ‘PayPal World' platform, which will integrate multiple payment systems, including UPI, Mercado Pago, Weixin Pay, and Venmo, so users can transact globally with their preferred wallets. This initiative will enable peer-to-peer (“P2P”) transactions between UPI and PayPal users worldwide, eliminating the need for credit cards and avoiding additional currency conversion and processing charges.

4. Sector Overview

4.1. NBFC poised to match banks by 2047 with focus on green finances and fair lending

NBFCs in India are expected to match scheduled commercial banks in credit disbursal by 2047 as part of the nation's “Viksit Bharat” vision. NBFCs have seen their credit growth outpace banks, accounting for nearly 25 per cent (twenty-five per cent) of bank advances in 2025, up from 21.84 per cent (twenty-one point eight four per cent) in 2019-20. The government is encouraging NBFCs to both scale up and direct at least half of their credit to high-growth and priority sectors such as green finance, including loans for solar panels, electric vehicles, sustainable agriculture, and energy startups.

4.2. Slowdown in credit growth despite RBI rate cuts

Despite the RBI's one percentage point policy rate cut in 2025, bank credit growth slowed to 9.8 per cent (nine point eight per cent), down from 14 per cent (fourteen per cent) last year, while deposits grew at 10.1 per cent (ten point one per cent). Retail loan growth weakened following RBI's tighter norms on unsecured loans and restrictions on NBFC funding, affecting vehicle, credit card, and other unsecured sectors. Credit demand from the formal sector, particularly housing, softened, and improved informal sector incomes reduced personal loan needs.

4.3. Sixty-five per cent of rural Indians get just two per cent of insurance branches; half of HNIs plan to switch insurers

Report released by the Insurance Brokers Association of India (“IBAI”) and McKinsey highlights a significant gap in India's insurance coverage, despite high banking penetration. While 65 per cent (sixty-five per cent) of India's population lives in rural areas, only 2 per cent (two per cent) of life insurance branches are located there, and life cover reaches less than 10 per cent (ten per cent) of rural residents, much lower than their high rate of bank account ownership. The rural 'missing middle, about 30 (thirty) crore people, remains largely uninsured, with less than 5 per cent (five per cent) of MSMEs having any coverage.

5. Business Updates

5.1. HDFC Bank tops credit card market, SBI leads in debit cards as of June 2025

HDFC Bank has maintained its position as the top credit card issuer in India, holding a 22 per cent (twenty-two per cent) market share in June 2025, while the State Bank of India (‘SBI”) continues to dominate debit cards with a 24 per cent (twenty-four per cent) share. In the debit card segment, Axis Bank and HDFC Bank led in year-on-year growth at 12 per cent (twelve per cent) and 8 per cent (eight per cent), respectively. Among debit cards, Bank of Baroda held 9 per cent (nine per cent), and Canara Bank, Union Bank, and HDFC Bank each held around 6 per cent (six per cent), while Bank of India, Axis Bank, and Punjab National Bank each accounted for 4 per cent (four per cent).

5.2. Debit card transaction volume slumps by 16 per cent

In June 2025, debit card transaction volumes in India fell sharply by 16 per cent (sixteen per cent) year-on-year, with the total value of transactions declining by about 10.6 per cent (ten point six per cent). In contrast, credit card transactions surged, showing a 28 per cent (twenty-eight per cent) year-on-year increase in volume and a 15 per cent (fifteen per cent) rise in transaction value. Monthly, debit card usage also dipped, with a 5 per cent (five per cent) drop in volumes and a 6.3 per cent (six point three per cent) decline in value from May to June 2025.

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