The RBI 2026 Directions are seven instruments.
On 31 July 2026 the Reserve Bank issued its Cybersecurity, Technology Risk, Resilience and Assurance Framework Directions as a separate instrument for each class of regulated entity. Treating them as one document is the commonest mistake we see. Here is what we have read, what we have not, and what the NBFC Directions ask.
Seven instruments, one date
Each set of Directions carries its own reference number, its own chapters and its own tiering. A bank's Directions do not bind an NBFC and a co-operative bank's levels are not an NBFC's layers. The table shows each instrument as it stands in AuditSahi's rulebook. Verified means we read the instrument in RBI's own publication. Unverified means we could not reach a primary page that quotes its title and reference, and the entry is shown that way in the product until we can.
| Instrument | Applies to | Reference | Status in our rulebook |
|---|---|---|---|
| Commercial banks | Scheduled commercial banks | RBI/DoS/2026-27/410 | verified |
| NBFCs | All NBFCs, by scale-based regulation layer and asset size | Master Direction of 31 July 2026 | verified |
| Urban co-operative banks | Primary co-operative banks, tiered by the digital services offered | RBI/DoS/2026-27/437 | verified |
| Small finance banks | Small finance banks | RBI/DoS/2026-27/419 | unverified |
| Payments banks | Payments banks | RBI/DoS/2026-27/428 | unverified |
| All-India financial institutions | AIFIs | Title reported in search results only | unverified |
| Credit information companies | CICs | Existence inferred from references to the seven | unverified |
Across the instruments we have read, the structure is the same: governance, policies, risk management, resilience, incident reporting and assurance, with the clauses applied by tier. The NBFC Directions are the ones most of our users meet, so the rest of this article follows them.
How the NBFC Directions tier
The NBFC Directions took effect on the day they were issued, 31 July 2026, with no transition period stated. Which chapters apply depends on the entity's layer under RBI's scale-based regulation and, within the Base Layer, on asset size.
| Layer | Who |
|---|---|
| Base Layer, below Rs 500 crore | Non-deposit taking NBFCs with assets under Rs 500 crore on the latest audited balance sheet |
| Base Layer, Rs 500 crore and above | Non-deposit taking NBFCs with assets of Rs 500 crore or more |
| Middle Layer | Deposit taking NBFCs irrespective of size, and non-deposit taking NBFCs of Rs 1,000 crore and above |
| Upper Layer | The top ten NBFCs by asset size, and others RBI places there by its scoring methodology |
| Top Layer | Reserved by RBI |
What a Base Layer NBFC of Rs 500 crore and above must do
AuditSahi's rulebook holds 90 obligations under the NBFC Directions. These are the ones a Board hears about first.
The Board must approve the technology and cybersecurity strategies and policies and review them at least annually.
Directions 2026, para 6An IT governance framework integrated with corporate governance, with documented roles for the Board, the IT Strategy Committee, the CEO, the CIO or CTO and the Risk Committee.
Directions 2026, paras 10 to 14Board-approved IT, information security and cybersecurity policies, the last setting out the strategy and approach to cyber threats in proportion to the business's complexity and risk appetite.
Directions 2026, paras 18, 20 to 22A Board-approved Cyber Crisis Management Plan covering detection, response, recovery and containment, with measures against the threats the Directions name, such as denial of service, ransomware and phishing.
Directions 2026, paras 25 to 27Cyber incidents reported to RBI on the DAKSH supervisory platform within six hours of detection.
Directions 2026, para 28The six-hour report to RBI sits beside the six-hour report to CERT-In under the 2022 Directions. One incident, two regulators, two clocks starting at about the same time.
What the smaller Base Layer NBFC must do
Below Rs 500 crore the Directions ask for less, but not for nothing. A Board-approved IT and information security policy covering access controls, passwords, user roles, maker-checker, digital signatures, mobile and social media use, management information for senior management and readiness for RBI returns, and a Board-approved business continuity plan with the Board seeing a report on it at least once a year.
Directions 2026, para 8 and para 8(8).
Why the distinction matters in an audit
An auditor reading the NBFC Directions against a policy written from a bank template will find clauses that do not apply and miss clauses that do. The instrument, the layer and the asset-size band decide the list, and the list decides the evidence. AuditSahi asks the three questions that place you, then shows the clause that put you there, so the document set you build is the one your own Directions ask for.
Sources
- Reserve Bank of India (Non-Banking Financial Companies: Cybersecurity, Technology Risk, Resilience and Assurance Framework) Directions, 2026, issued 31 July 2026. rbidocs.rbi.org.in
- Reserve Bank of India (Commercial Banks: Cybersecurity, Technology Risk, Resilience and Assurance Framework) Directions, 2026, RBI/DoS/2026-27/410. rbi.org.in
- Reserve Bank of India (Urban Co-operative Banks: Cybersecurity, Technology Risk, Resilience and Assurance Framework) Directions, 2026, RBI/DoS/2026-27/437. rbi.org.in
- Small finance banks, RBI/DoS/2026-27/419, and payments banks, RBI/DoS/2026-27/428: reference numbers recorded, full text not yet verified against a primary page. rbi.org.in
Clauses quoted from the NBFC Directions are marked verified in AuditSahi's rulebook. The AIFI and CIC instruments are held as unverified and are shown that way in the product.
AuditSahi holds each of the RBI Directions as its own instrument and places an NBFC by layer and asset size, with the clause that says so.
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