RBI Integrated Ombudsman Scheme 2026: How to Complain Against a Bank or NBFC
RB-IOS 2026, in force from 1 July 2026: who is covered, the 30-day and 90-day windows, the ₹30 lakh and ₹3 lakh caps, rejection grounds and the appeal.
The Reserve Bank – Integrated Ombudsman Scheme, 2026 (RB-IOS 2026) came into force on 1 July 2026 and replaced the Reserve Bank – Integrated Ombudsman Scheme, 2021. The Reserve Bank issued it on 16 January 2026, after publishing a draft on 7 October 2025 for public comment. It is made under Section 35A of the Banking Regulation Act, 1949, Section 45L of the Reserve Bank of India Act, 1934, Section 18 of the Payment and Settlement Systems Act, 2007 and Section 11 of the Credit Information Companies (Regulation) Act, 2005.
The Scheme is free, summary and non-adversarial. It is also strict about who may use it, when, and for what. The threshold conditions are where a complaint is most easily lost — filed too late, filed without first approaching the lender, filed through an advocate, or about a matter the Scheme excludes. This note sets out the coverage, the time windows, the grounds of rejection, the procedure, the compensation limits and the appeal, clause by clause.
Key points
- Complain to the bank or NBFC first, in writing or another mode you can prove.
- Wait 30 days (or the longer period fixed by RBI, NPCI or card network rules), unless the entity replies earlier and you are dissatisfied.
- File with the RBI Ombudsman within 90 days from the end of that waiting period or the entity's last communication, whichever is later. The 2021 Scheme allowed one year.
- Compensation: up to ₹30 lakh for consequential loss, plus up to ₹3 lakh for time, expenses, harassment and mental anguish. There is no limit on the amount in dispute.
- File online at cms.rbi.org.in, by email to crpc@rbi.org.in, or by post to the Centralised Receipt and Processing Centre in Chandigarh. There is no fee.
- An advocate cannot act as authorised representative unless the advocate is the aggrieved person.
- An appeal lies only against an Award, within 30 days of receiving it.
- Complaints received before 1 July 2026 continue under the 2021 Scheme.
Which banks and NBFCs does RB-IOS 2026 cover?
Clause 1(3) lists the entities covered. The Scheme uses the term "Regulated Entity" for all of them.
| Category | Covered under clause 1(3) |
|---|---|
| Banks | All commercial banks, regional rural banks, state and central co-operative banks, and scheduled primary (urban) co-operative banks |
| Non-scheduled urban co-operative banks | Only with deposits of ₹50 crore and above on the previous year's audited balance sheet |
| NBFCs | Those authorised to accept deposits, or with a customer interface and assets of ₹100 crore and above |
| Excluded NBFCs | Housing finance companies, CICs, IDF-NBFCs, NBFC-IFCs, NOFHCs, primary dealers, mortgage guarantee companies |
| Others | Non-bank prepaid payment instrument issuers, and credit information companies |
The definitions narrow coverage further. A bank "in resolution or winding up or under All-Inclusive Directions" is outside the definition of bank, and an NBFC in resolution, winding up or liquidation, or under directions of the Reserve Bank, is outside the definition of NBFC.
What counts as a complaint under the Scheme?
Clause 3(1)(f) defines a complaint as a representation in writing alleging a deficiency in service on the part of a Regulated Entity, submitted by its customer or an authorised representative, and seeking relief under the Scheme.
"Deficiency in service" in clause 3(1)(i) means a shortcoming or inadequacy in any service which the entity is required to provide statutorily or otherwise, whether or not it results in financial loss. "Customer" in clause 3(1)(h) includes an applicant for a service, so a person refused or kept waiting on an application is a customer.
In deciding a complaint, the Ombudsman takes into account the principles of banking law and practice and the directions, instructions, guidelines and regulations issued by the Reserve Bank (clause 8(2)). That is why the strongest complaints identify the specific RBI instruction the entity failed to follow. The complaint form in the Annex lists the common categories, including loans and advances (with complaints against recovery agents and direct sales agents, harassment and non-observance of the Fair Practices Code), mis-selling, KYC-related freezing of accounts, internet and mobile banking, credit and debit cards, and pensions. For lending complaints, the obligations most often in issue are discussed in the notes on RBI digital lending directions and recovery agent harassment.
When can you approach the RBI Ombudsman?
Clause 10(1) sets cumulative conditions. The timing conditions are these:
- First approach the entity. The complainant must have complained to the Regulated Entity, in writing or through any other mode, and be able to produce proof of having done so (clause 10(1)(e)). A complaint in which the Reserve Bank is merely copied does not count as a complaint to the Ombudsman (clause 10(1)(a)).
- Wait, or be dissatisfied. The complainant must not have received a reply within 30 days of the entity receiving the complaint, or within any longer time fixed by the Reserve Bank, NPCI or card network guidelines, whichever is higher — or must be dissatisfied with the reply or resolution (clause 10(1)(f)).
- File within 90 days. The complaint must reach the Ombudsman within 90 days from the date on which that waiting period expires, or the date of the last communication from the entity, whichever is later (clause 10(1)(g)).
- Limitation. The original complaint to the entity must have been made within the limitation period under the Limitation Act, 1963 for such claims (clause 10(1)(l)).
| Stage | What happens | Scheme reference |
|---|---|---|
| Day 0 | Complaint lodged with the bank or NBFC; keep proof | Clause 10(1)(e) |
| Day 30 (or longer prescribed period) | Waiting period ends if there is no reply | Clause 10(1)(f) |
| Any reply received | Dissatisfied complainant may proceed | Clause 10(1)(f) |
| 90 days after the later of the two dates | Last day to file with the RBI Ombudsman | Clause 10(1)(g) |
The 90-day window is the most important practical change. Under the 2021 Scheme, a complainant had one year from the entity's reply, or one year and 30 days from the complaint where no reply came. A borrower who waits for a negotiation to run its course can now lose the Ombudsman route altogether. Because the window runs from the later of the two dates, a further written communication from the entity moves the "last communication" date on; that is one more reason to keep every exchange in writing and dated.
Which complaints are rejected at the outset?
Clause 10(1) also makes a complaint non-maintainable if it is abusive, frivolous or vexatious; if it lacks the information the Annex form requires; if it is filed through an advocate who is not the aggrieved person; or if the same grievance is pending before, or has been settled or decided on merits by, the Ombudsman's office or any court, tribunal, arbitrator or other judicial or quasi-judicial forum. Explanation 1 to clause 10 provides that a pending or decided criminal proceeding, or a police investigation, is not treated as the same grievance for this purpose.
Clause 10(2) then excludes certain subject-matter entirely:
- a commercial judgment or decision of the entity;
- a dispute between a vendor and the entity;
- grievances against the entity's management or executives;
- action taken by the entity in compliance with orders of a judicial, quasi-judicial, statutory or law enforcing authority;
- a service outside the Reserve Bank's regulatory purview;
- disputes between Regulated Entities;
- employer-employee disputes;
- grievances for which Section 18 of the Credit Information Companies (Regulation) Act, 2005 provides a remedy;
- grievances of customers of an entity not included in the Scheme.
The commercial-judgment exclusion matters most to borrowers. A refusal to sanction a loan, or to restructure one, is likely to be treated as a commercial decision. A failure to follow the RBI's procedural instructions while making or communicating that decision is a service matter. The complaint should be framed around the second.
How do you file a complaint?
Clause 11 and the Annex provide three channels, all free of charge:
1. Online through the Complaint Management System at cms.rbi.org.in.
2. By email to crpc@rbi.org.in.
3. By post or hand delivery of the signed Annex form to the Centralised Receipt and Processing Centre, Reserve Bank of India, 4th Floor, Sector 17, Central Vista, Chandigarh 160017.
The documents normally required are the complaint made to the entity, its reply if any, and any other supporting documents. The Annex form asks for the entity's complaint reference number, the account or card details, transaction references, the relief sought, and, if compensation is claimed, separate figures for consequential loss (maximum ₹30 lakh) and for time, expenses, harassment and mental anguish (maximum ₹3 lakh) with calculations. The complainant categories in the form include individuals, senior citizens, persons with disabilities, proprietorships, partnerships, MSMEs, trusts and limited companies, so small businesses can use the Scheme.
The Reserve Bank's contact centre on toll-free number 14448 gives guidance on filing and status, but complaints cannot be filed through it.
What happens after the complaint is filed?
The proceedings are summary and are not bound by rules of evidence (clause 14(1)).
Scrutiny. Online complaints undergo limited system-based validation for basic maintainability; email and physical complaints are checked by the Centralised Receipt and Processing Centre (clause 12). Registration is not a finding that the complaint is maintainable, and the Ombudsman can still reject it later (clause 12(5)).
Response. The complaint is forwarded to the entity, which must file its written response with the documents it relies on within 15 days, extendable on written request (clause 14(2)). If it fails to respond, the Ombudsman may proceed ex parte and pass an Award (clause 14(3)).
Settlement. The Ombudsman or Deputy Ombudsman tries to facilitate settlement, may issue an advisory to the entity, and may convene a conciliation meeting held in the Ombudsman's presence, in person or online (clauses 14(4) to 14(7)). A complaint is closed when it is fully settled, when the complainant accepts the resolution, on withdrawal, or when the Ombudsman finds the complainant's objections to the resolution without sufficient merit (clause 14(8)).
Award. Where the matter is not resolved, and the complaint is not rejected, the Ombudsman passes an Award after giving both parties a reasonable opportunity of being heard, orally or in writing (clause 15(1)).
How much compensation can be awarded?
Clause 8(3) provides that there is no limit on the amount in dispute that can be brought before the Ombudsman. For consequential loss, the Ombudsman may award compensation up to ₹30 lakh. In addition, the Ombudsman may award up to ₹3 lakh for the complainant's loss of time, expenses incurred, and harassment or mental anguish. The corresponding limits under the 2021 Scheme were ₹20 lakh and ₹1 lakh.
A complaint that seeks consequential-loss compensation beyond the Ombudsman's power can be rejected under clause 16(2)(b), so the claim should be pitched within the caps or the forum chosen differently.
Clause 16 also permits rejection at any stage where there is no deficiency in service, where the complaint is not pursued with reasonable diligence, where it is without sufficient cause, where it requires elaborate documentary and oral evidence unsuited to these proceedings, where there is no loss, damage or inconvenience, or where a case on the same cause of action is filed in a court or tribunal while the complaint is pending.
How do you accept or appeal an Award?
An Award lapses unless the complainant sends the entity a letter accepting it in full and final settlement within 30 days of receiving it (clause 15(4)). The entity must then comply, and intimate compliance to the Ombudsman, within 30 days of receiving the acceptance letter, unless it appeals where an appeal is permitted (clause 15(5)).
Clause 17 governs appeals to the Appellate Authority, the Executive Director in charge of the Reserve Bank's Consumer Education and Protection Department:
- A complainant aggrieved by an Award may appeal within 30 days of receiving it, extendable by up to 30 days for sufficient cause. A complainant who appeals cannot also accept the Award.
- An entity may appeal against an Award passed after examination on the merits, within 30 days of receiving the complainant's acceptance letter, and only with the previous sanction of its Executive Director or an official of equal rank.
- An entity has no appeal against an Award passed because it failed to furnish documents or information.
The Appellate Authority may dismiss the appeal, set the Award aside, remand the matter, modify the Award, or pass any other order it thinks fit. The Reserve Bank's published FAQs on the Scheme confirm that an appeal is available only against an Award, so a rejected complaint has no appeal within the Scheme.
What if the Ombudsman route does not fit?
The Scheme is one forum among several. Matters needing detailed evidence, claims beyond the caps, and challenges to enforcement under the SARFAESI Act belong elsewhere — the last before the Debts Recovery Tribunal, as explained in the notes on replying to a SARFAESI Section 13(2) notice and the Debts Recovery Tribunal. A complaint about the classification of an account is also usually better dealt with under the specific procedure governing it, discussed in the notes on wrongful NPA classification and fraud classification of a borrower account.
Two sequencing points follow from the text. Filing a civil suit, consumer complaint or other proceeding on the same cause of action while the Ombudsman complaint is pending allows the Ombudsman to reject it (clause 16(1)(c)). And a grievance already pending before a court or tribunal cannot be brought to the Ombudsman at all (clause 10(1)(j)). The forum should therefore be chosen before the first filing, not after.
Clause 20(2) preserves the 2021 Scheme for complaints received before 1 July 2026, for appeals from decisions under it, and for execution of its Awards.
Borrower-side matters are dealt with under banking disputes. This article is general information on the Scheme and is not legal advice; whether a complaint is maintainable depends on its facts and dates. Queries may be sent through the contact page.
Frequently Asked Questions
What is the time limit to complain to the RBI Ombudsman under the 2026 Scheme?
You must first complain to the bank or NBFC. If it does not reply within 30 days, or a longer period fixed by RBI, NPCI or card network rules, or if you are dissatisfied with its reply, you may approach the RBI Ombudsman within 90 days from the expiry of that period or from the entity's last communication, whichever is later. The 2021 Scheme allowed one year.
How much compensation can the RBI Ombudsman award under RB-IOS 2026?
There is no limit on the amount in dispute. For consequential loss, the RBI Ombudsman may award compensation up to ₹30 lakh, and separately up to ₹3 lakh for the complainant's loss of time, expenses, harassment or mental anguish. Under the 2021 Scheme the corresponding limits were ₹20 lakh and ₹1 lakh. A claim beyond the cap can be rejected.
Can a lawyer file a complaint with the RBI Ombudsman?
Not as a representative. Clause 10(1)(b) of the 2026 Scheme makes a complaint maintainable only if lodged by the complainant personally or through an authorised representative other than an advocate, unless the advocate is the aggrieved person. A complainant may still take legal advice before filing and may authorise a non-advocate representative in writing using the Annex form.
Can I appeal if the RBI Ombudsman rejects my complaint?
Under RB-IOS 2026 an appeal lies only against an Award. A complainant aggrieved by an Award may appeal to the Appellate Authority, the Executive Director in charge of RBI's Consumer Education and Protection Department, within 30 days of receiving it, extendable by up to 30 days for sufficient cause. The Scheme does not provide an appeal against a rejection.
Are housing finance companies covered by the RBI Ombudsman Scheme 2026?
No. Clause 1(3)(b) excludes Housing Finance Companies, along with Core Investment Companies, IDF-NBFCs, NBFC-IFCs, Non-Operative Financial Holding Companies, Primary Dealers and Mortgage Guarantee Companies. Other NBFCs are covered if they accept deposits, or have a customer interface and assets of ₹100 crore or more on the previous year's audited balance sheet.
Speak with Advocate Subodh Bajpai
Advocate Subodh Bajpai practises at the Delhi High Court as Senior Partner of Unified Chambers And Associates. Practice areas: debt recovery and insolvency (SARFAESI, DRT, IBC, Section 138, commercial litigation) and white-collar criminal defence (PMLA, CBI, bail and quashing).
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Notes on Indian law by Advocate Subodh Bajpai, written from the statute. General information, not legal advice.