AKP Banking & Finance Digest November 17, 2025

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1.             Regulatory Updates

1.1.         India

Reserve Bank of India (RBI)

1.1.1.    RBI recognises Self-Regulated PSO Association as SRO for Payment System Operators

Reserve Bank of India (“RBI”) recognised the Self-Regulated PSO Association (SRPA) as a Self-Regulatory Organisation (“SRO”) for Payment System Operators (“PSOs”). This recognition follows the Framework for Recognition of Self-Regulatory Organisation for Payment System Operators issued on October 22, 2020, and the ‘Omnibus framework for recognition of SROs for Regulated Entities of the Reserve Bank’ issued on March 21, 2024, which invited eligible associations to apply. The move formalises an industry body to set and monitor standards for PSOs, strengthening governance, compliance, and risk management across India’s payments ecosystem.

1.1.2.    RBI issued the Master Direction – Reserve Bank of India (Repurchase Transactions) Directions, 2025

RBI issued the Master Direction – Reserve Bank of India (Repurchase Transactions (“Repo”)) Directions, 2025, bringing Municipal Debt Securities (“MDS”) into the list of eligible repo collateral following a Central Government notification under the Reserve Bank of India Act, 1934. The Directions take immediate effect and cover transactions on recognised stock exchanges, authorised electronic trading platforms, and over-the-counter markets; require off-platform trades to be reported within 15 (fifteen) minutes to Clearcorp Repo Order Matching System (CROMS) for government securities and to F-TRAC for other eligible securities; mandate Delivery versus Payment (DvP) settlement; and set minimum haircuts of 2 per cent (two per cent) for listed corporate bonds, debentures and MDS, and 1.5 per cent (one point five per cent) for Commercial Papers (CPs) and Certificates of Deposit (CDs). Banks’ repos in government securities remain exempt from Cash Reserve Ratio (“CRR”) and Statutory Liquidity Ratio (“SLR”) computation, while repos in corporate bonds count toward CRR/SLR, and eligible participants include regulated entities, listed corporates and All India Financial Institutions, with the 2018 framework and related circulars superseded.

1.1.3.    RBI notifies the Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025 and issued the Reserve Bank of India (Trade Relief Measures) Directions, 2025

RBI notified the Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025 and issued the Reserve Bank of India (Trade Relief Measures) Directions, 2025 to support exporters facing global trade disruptions. The amendment to the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015 extends the period for realisation and repatriation of export proceeds from 9 (nine) months to 15 (fifteen) months and increases the time for shipment of goods against advance payments from 1 (one) year to 3 (three) years. The Trade Relief Measures Directions, 2025 apply to regulated entities including commercial banks, cooperative banks, non-banking financial companies (“NBFCs”), all-India financial institutions and credit information companies (CICs), and allow a moratorium on term-loan instalments and deferment of interest on working capital falling due between September 1, 2025 and December 31, 2025, extension of pre-shipment and post-shipment export credit tenor to 450 (four hundred and fifty) days for credit disbursed till March 31, 2026, and liquidation of certain packing credit from alternate legitimate sources, while requiring a general provision of at least 5 (five) per cent of outstanding amounts on eligible standard export credit accounts.

1.1.4.    RBI updates UAPA Section 51A compliance after UNSC delisting of two ISIL entries

RBI has issued a circular dated November 14, 2025, to all regulated entities (“REs”) reminding them of their obligations under the Unlawful Activities (Prevention) Act, 1967 (“UAPA”). The circular notes that the Ministry of External Affairs (MEA) has informed RBI about a United Nations Security Council (UNSC) decision, via press release SC/16214 dated November 6, 2025. Under this decision the Security Council Committee has removed two named individuals from its Islamic State in Iraq and the Levant (ISIL/Da’esh) and Al-Qaida sanctions list pursuant to Resolution 2799 (2025) and earlier resolutions. REs are instructed to take appropriate action by updating their customer and account screening in line with the revised United Nations sanctions lists, and to continue following the procedure laid down in the UAPA Order dated February 2, 2021, as amended on April 22, 2024, including use of the updated online lists maintained by the United Nations. The circular further reiterates that any delisting request received by an RE must be forwarded electronically to the Joint Secretary (Counter Terrorism and Counter Radicalization) in the Ministry of Home Affairs (MHA), and that individuals or entities may also approach the independent Ombudsperson appointed by the United Nations Secretary-General under the ISIL (Da’esh) and Al-Qaida sanctions regime.

1.1.5.    Two NBFCs surrender their Certificate of Registration to RBI

The following 2 NBFCs have surrendered the Certificate of Registration (“CoR”) granted to them by the RBI. The RBI, in exercise of powers conferred on it under Section 45-IA (6) of the Reserve Bank of India Act, 1934, has therefore cancelled their CoR:

Sr. No.	Name of the Company	Registered Office Address	CoR No.	CoR Issued On	Cancellation Order Date
1.	Parichay Commotrade Pvt Ltd	101, Prime Plaza, S.V. Road, Santa Cruz (West), Mumbai-400054	B-13.02358	August 05, 2019	October 15, 2025
2.	Renuka Investments and Finance Limited	PO Renukoot Sonbhadra, Uttar Pradesh, 231217	12.00046	February 27, 1998	October 16, 2025

1.1.6.    RBI cancels Certificate of Registration of two NBFCs

RBI, in exercise of powers conferred on it under Section 45-IA (6) of the Reserve Bank of India Act, 1934, has cancelled the Certificate of Registration of the following companies:

Sr. No.	Name of the Company	Registered Office Address	CoR No.	CoR Issued On	Cancellation Order Date
1.	Jumbo Finvest (India) Limited	102, Kanchan Apartment, Opp. L.B.S College, Tilak Nagar, Raja Park, Jaipur, Rajasthan-302004	B-10.00186	October 24, 2011	October 14, 2025
2.	Champion Agro Finance Limited	A/1/301, Shree Apartment, Veraval Main Road, Veraval (Shapar), Kotda Sangani, Rajkot, Gujarat - 360024	01.00252	August 02, 2010	October 15, 2025

Securities and Exchange Board of India (SEBI)

1.1.7.     SEBI issues Consultation Paper on amendments to SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018

Securities and Exchange Board of India (“SEBI”) has issued a consultation paper proposing amendments to the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018 (Issue of Capital and Disclosure Requirements (ICDR) Regulations) to ease public issue processes and increase retail participation in Initial Public Offers (“IPOs”). The paper proposes an enabling framework for pre-issue capital held by non-promoters, under which pledged shares would be treated as subject to lock-in by amending the issuer’s Articles of Association so that such equity shares remain locked for the applicable period in the hands of the pledgor or pledgee, with depositories marking them as non-transferable where a technical lock-in cannot be created, thereby resolving operational difficulties while protecting lenders and after discussions with select Non-Banking Financial Companies (NBFCs) that lend against unlisted shares. SEBI also proposes to rationalise and elevate the Offer Document Summary (ODS) into a focused, standardised disclosure document accompanying the Draft Red Herring Prospectus (DRHP), Red Herring Prospectus (RHP), Further Public Offers (FPOs) and Small and Medium Enterprises (SME) IPOs, to be hosted separately on the websites of issuers, SEBI, stock exchanges and lead managers and accessed via quick response (QR) codes and links in application forms, with streamlined contents highlighting business and industry summaries, key risks, financial information and key performance indicators in place of the current abridged prospectus. Public comments on the proposals, including the treatment of pledged shares and the replacement of the abridged prospectus with the Offer Document Summary (ODS), have been invited through SEBI’s web-based public comments form or by e-mail, to be submitted on or before December 4, 2025.

1.1.8.     SEBI proposes ethics and conflict-of-interest overhaul

SEBI constituted a High-Level Committee (“HLC”) on March 24, 2025. The HLC submitted its report to the SEBI Chairperson on November 10, 2025. Its Terms of Reference covered recusals, public disclosures, restrictions on investments, maintenance of digital records, monitoring, and a public complaints mechanism. The report recommends classifying the Chairperson and Whole-Time Members (WTMs) as insiders under the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015. It provides options to liquidate or freeze pre-existing holdings and prohibits gifts. It also sets a formal recusal framework backed by a digital repository and public transparency. It further proposes an Office of Ethics and Compliance led by a Chief Ethics and Compliance Officer and overseen by an independent Oversight Committee on Ethics and Compliance. It adds an anonymous whistleblower channel, mandatory training, and technology-enabled monitoring using artificial intelligence, to be operationalised through new regulations for Board Members and amendments for employees.

International Financial Services Centres Authority (IFSCA)

1.1.9.     IFSCA issues Consultation Paper on Regulatory Framework for Implementation Services by Investment Advisers in IFSC

International Financial Services Centres Authority (“IFSCA”) has issued a consultation paper proposing a detailed framework to govern “implementation services” provided by Investment Advisers (“IAs”) registered under the International Financial Services Centres Authority (Capital Market Intermediaries) Regulations, 2025 (“CMI Regulations”) in the International Financial Services Centre (“IFSC”). The draft circular clarifies that IAs may route client implementation in financial products listed on stock exchanges in foreign jurisdictions only through a Global Access Provider registered with IFSCA, while products or securities listed on a recognised stock exchange in the IFSC must be accessed through a broker dealer registered with IFSCA. For other investment products or securities, IAs may enter into formal arrangements with platforms or asset management companies that are registered or regulated in foreign jurisdictions by an appropriate financial sector regulator. The framework reiterates that implementation services must remain purely optional for advisory clients, in line with the CMI Regulations, ensuring that advice and execution are not bundled in a coercive manner. Public comments on the draft circular, including on the proposed routing channels and client-protection safeguards, have been invited by e-mail to the specified IFSCA officials on or before December 3, 2025.

1.1.10.  IFSCA directs IBUs to include Vostro balances in BAL reporting

IFSCA on November 11, 2025, issued additional directions for IFSC Banking Units (“IBUs”). IBUs must report balances of overseas banks’ Vostro accounts held with them in the Banking Asset Liability (BAL) statement on the Balance of Payments (BoP) portal on a fortnightly basis from the second fortnight of November 2025. The annexed format requires reporting either the net credit or the net debit position for current accounts and capturing the country and currency. These instructions add to existing reporting to the RBI. Non-compliance will be viewed seriously under powers in the Banking Regulation Act, 1949 and the International Financial Services Centres Authority Act, 2019.

Miscellaneous

Ministry of Corporate Affairs (MCA)

1.1.11.  MCA announces downtime for V3 Enforcement Module launch

Ministry of Corporate Affairs (“MCA”) has notified that the Version 3 (“V3”) MCA portal will be unavailable from November 15, 2025, 9:00 PM to November 16, 2025, 9:00 AM for the launch of the V3 Enforcement Module, and has advised stakeholders to plan their work accordingly.

Telecom Regulatory Authority of India (TRAI)

1.1.12.  TRAI seeks comments on POI surrender and bank-guarantee norms for interconnection

Telecom Regulatory Authority of India (TRAI) is consulting on interconnection changes that include introducing a formal surrender process for Points of Interconnection (POI) and revising the existing disconnection procedure, which could reshape financial safeguards between carriers. It also re-examines the requirement that a Telecom Service Provider (“TSP”) furnish a bank guarantee (BG) to another TSP to secure interconnection liabilities such as Interconnection Usage Charges (IUC).

Ministry of Electronics and Information Technology (MeitY)

1.1.13.  MeitY operationalises DPDP framework with Rules and Data Protection Board

On November 13, 2025, the Ministry of Electronics and Information Technology (MeitY) issued a set of notifications that operationalise the Digital Personal Data Protection Act, 2023 (DPDP Act), including finalising the Digital Personal Data Protection Rules, 2025 (DPDP Rules) with staggered commencement dates, under which some provisions take effect on publication in the Official Gazette, others after 1 (one) year and the remainder after 18 (eighteen) months.  At the same time, the Central Government appointed different commencement dates for various provisions of the DPDP Act, bringing certain foundational, regulatory and penalty-related sections into force immediately, with specific additional provisions becoming effective after 1 (one) year and the bulk of operative obligations and rights, including sections 3 to 5, 7 to 17 and associated enforcement machinery, commencing after 18 (eighteen) months from the date of publication. The notifications also establish the Data Protection Board of India (Board), specify that its head office will be located in the National Capital Region (NCR) of India, and provide that the Board will consist of 4 (four) members. Taken together, these measures set out the institutional framework and clear implementation timelines for India’s new personal data protection regime, giving data fiduciaries and data processors a defined runway to plan and implement compliance.

National Payments Corporation of India (NPCI)

1.1.14.  NPCI enables ISD-GSTIN option for UPI GST reporting

The National Payments Corporation of India (NPCI) has added an Input Service Distributor – Goods and Services Tax Identification Number (“ISD-GSTIN”) option in its Unified Payments Interface (UPI) back-office for Goods and Services Tax (“GST”) reporting. Members may choose standard GSTIN or ISD-GSTIN, with changes reflected in the same month’s GST reports if updated on or before the 20th (twentieth) of the month; updates after the 20th (twentieth) take effect from the following month. The functionality goes live on November 17, 2025. Existing GSTIN settings captured at onboarding remain valid if Input Service Distributor (“ISD”) is not selected, and ISD applies to all income and fee types including Switching Fee, Interchange Fee, and Payment Service Provider (PSP) Fee, supported by a maker-checker workflow in the annexed steps.

Monetary Penalties

1.1.15.  RBI imposes penalties on five banks for regulatory non-compliance

RBI has imposed monetary penalties on the following institutions:

Sr. No.	Name of Bank	Amount of Penalty	Grounds for Penalty
1.	The Mumbai District Central Co-operative Bank Ltd., Maharashtra	INR 2,00,000 (Indian Rupees Two Lakh only)	Contravention of provisions of Section 20 of the Banking Regulation Act, 1949. This penalty has been imposed in exercise of powers conferred on RBI under the provisions of Section 47A(1)(c) read with Sections 46(4)(i) and 56 of the Banking Regulation Act, 1949.
2.	The Karaikudi Co-operative Town Bank Limited, Tamil Nadu	INR 1,50,000 (Indian Rupees One Lakh Fifty Thousand only)	Non-compliance with certain directions issued by RBI on ‘Prudential Norms on Capital Adequacy - Primary (Urban) Co-operative Banks (UCBs)’ and ‘Know Your Customer (KYC)’. This penalty has been imposed in exercise of powers conferred on RBI under the provisions of Section 47A(1)(c) read with Sections 46(4)(i) and 56 of the Banking Regulation Act, 1949.
3.	The District Co-operative Central Bank Limited, Eluru, Andhra Pradesh	INR 50,000 (Indian Rupees Fifty Thousand only)	Non-compliance with certain directions issued by RBI on ‘Know Your Customer (KYC)’. This penalty has been imposed in exercise of powers conferred on RBI under the provisions of Section 47A(1)(c) read with Sections 46(4)(i) and 56 of the Banking Regulation Act, 1949.
4.	The Mettupalayam Co-operative Urban Bank Limited, Tamil Nadu	INR 1,50,000 (Indian Rupees One Lakh Fifty Thousand only)	Non-compliance with certain directions issued by RBI on ‘Loans and advances to directors, their relatives, and firms /concerns in which they are interested’ and ‘Exposure Norms and Statutory / Other Restrictions – UCBs’. This penalty has been imposed in exercise of powers conferred on RBI under the provisions of Section 47A(1)(c) read with Sections 46(4)(i) and 56 of the Banking Regulation Act, 1949.
5.	Tamilnad Mercantile Bank Limited	INR 39,60,000 (Indian Rupees Thirty Nine Lakh Sixty Thousand only)	Contravention of provisions of section 10A of Payment and Settlement Systems Act, 2007 (PSS Act) and section 26A of the Banking Regulation Act, 1949. This penalty has been imposed in exercise of powers conferred on RBI under the provisions of section 30(1) read with section 26(6) of the PSS Act and section 47A(1)(c) read with section 46(4)(i) of the Banking Regulation Act, 1949.

2.             Key Asian Markets - Philippines and Vietnam

2.1.         Philippines

2.2.1.     Philippines FDI net inflow USD 494 million in August

Bangko Sentral ng Pilipinas (“BSP”) reported net Foreign Direct Investment (“FDI”) inflows of United States dollars (USD) 494 million (United States Dollars Four Hundred Ninety-Four Million only) in August 2025. This was 40.5 per cent (forty point five per cent) lower than USD 830 million (United States Dollars Eight Hundred Thirty Million only) in August 2024. Year to date (YTD), January–August 2025 FDI totalled USD 5.2 billion (United States Dollars five point two billion only), 22.5 per cent (twenty-two point five per cent) below USD 6.7 billion (United States Dollars six point seven billion only) a year earlier. The BSP said inflows were concentrated in manufacturing, wholesale and retail trade, and real estate, with equity placements mainly from Japan, the United States, Singapore and South Korea, and viewed the outturn as supportive of external resilience.

2.2.2.     BSP calls for 24/7 real-time settlement via PhilPaSSplus

BSP asked payment-system participants to help design a round-the-clock Real-Time Gross Settlement (“RTGS”) capability on its PhilPaSSplus platform. The goal is to move beyond weekday operating hours and enable continuous settlement of domestic payments, remittances, cross-border e-commerce flows, and bond trading. The call was made at the “2025 Peso RTGS Forum” in Manila on September 18–19, 2025, and in North Luzon on October 2, 2025. The plan includes refinements to operating rules for holidays and work suspensions, stronger penalties for erring Peso RTGS participants, and alignment with the International Organization for Standardization (ISO) 20022 messaging standard. Banks, quasi-banks, non-bank e-money issuers, financial market infrastructures, and clearing operators were invited to support resilience and risk management improvements.

2.3.         Vietnam

2.3.1.   SBV issues new circular on overseas foreign currency accounts for resident organisations

State Bank of Vietnam (“SBV”) has issued Circular No. 39/2025/TT-NHNN, signed on October 31, 2025, setting out the rules for opening and using foreign currency accounts abroad by resident organisations. Building on Circular No. 20/2015/TT-NHNN, the new circular streamlines administrative procedures, reduces dossier requirements and promotes the handling of licensing through electronic and digital channels in line with Resolution No. 66/NQ-CP dated March 26, 2025, on cutting and simplifying business-related administrative procedures for 2025–2026. The circular comprises 6 (six) Chapters and 19 (nineteen) Articles regulating eligible cases, licence terms, application and amendment procedures, automatic expiry and revocation of licences, and the responsibilities of relevant units, and will take effect from December 15, 2025.

2.3.2.     Vietnam USD interbank rates ease

SBV reported that during November 3–7, 2025, average United States Dollar (USD) interbank rates in Vietnam fell. Overnight ended at 3.89 per cent (three point eight nine per cent) and one week at 3.93 per cent (three point nine three per cent), down by 0.12 (zero point one two) and 0.10 (zero point one zero) percentage points. USD trading was concentrated in the overnight tenor at 88 per cent (eighty-eight per cent).

3.             Trends

3.1.         SEBI plans sweeping reforms to woo foreign investors

SEBI chair said the regulator is planning a package of changes to attract foreign portfolio investors, including faster registration, lower trading costs in the cash equity market, easier short-selling and possible tweaks to “netting” rules that would cut capital tied up in trades. The proposals are also aimed at rebalancing India’s markets, where derivatives volumes dwarf cash trading, and may be accompanied by curbs on excessive derivatives speculation by retail investors. SEBI has already dropped its earlier push for same-day (T+0) settlement but is still evaluating other reforms, so the final shape and timing of the rule changes remain uncertain.

3.2.         IndusInd Bank clawback move may test strength of misconduct rules

IndusInd Bank has started a process to claw back salary and bonuses from its former chief executive and deputy chief after an internal review found incorrect accounting on derivative trades that triggered a USD 230 million (United States Dollars Two Hundred Thirty Million only) hit and regulatory investigations, with the board reportedly seeking legal opinions under its own code of conduct and RBI guidelines; clawback provisions have existed in Indian banking contracts since 2019 but have rarely been used, so the still-uncertain outcome of this case could set an important precedent for how aggressively banks across the sector enforce pay clawbacks in future misconduct situations.

4.             Business Updates

4.1.         Mahindra & Mahindra and Manulife announce life insurance JV in India

Mahindra & Mahindra Limited (M&M) and Canadian financial services group Manulife have agreed to form a 50:50 (fifty-fifty) life insurance joint venture (“JV”) in India, with a planned capital commitment of up to INR 7,200 crore (Indian Rupees Seven Thousand Two Hundred Crore only), equally split at up to INR 3,600 crore (Indian Rupees Three Thousand Six Hundred Crore only) each. The partners intend to invest about INR 1,250 crore (Indian Rupees One Thousand Two Hundred and Fifty Crore only) each over the first 5 (five) years to build out the new insurer, subject to regulatory approvals. The JV will leverage Mahindra’s domestic distribution network and Manulife’s global insurance expertise to offer protection and savings products, especially in underpenetrated rural and semi-urban markets. The move deepens their existing asset management partnership and marks a further expansion of both groups into India.

4.2.         Promoter group raises stake in SBI Life-backed NBFC Paisalo Digital

Equilibrated Ventures CFlow Private Limited, part of the promoter group of Paisalo Digital Limited, a non-banking financial company (NBFC), has acquired about 43.94 lakh (Forty-Three Lakh Ninety-Four Thousand) equity shares through open-market purchases executed on November 13, 2025, increasing its holding by 0.48 per cent (zero point four eight per cent). Following this transaction, Equilibrated Ventures CFlow’s stake in Paisalo Digital stands at 20.42 per cent (twenty point four two per cent), and the promoter group’s aggregate shareholding rises to 18.57 crore (Eighteen Crore Fifty-Seven Lakh) shares, while the company’s total equity share capital remains at INR 90 crore (Indian Rupees Ninety Crore only). The promoter buying comes alongside a reported 13.5 per cent (thirteen point five per cent) year-on-year rise in net profit to INR 52 crore (Indian Rupees Fifty-Two Crore only) for the second quarter of the financial year 2025–26 (FY 2025–26), even as the stock has lost around 55 per cent (fifty-five per cent) of its value over recent months. The deal signals continued promoter confidence in the NBFC’s growth prospects within India despite recent share price weakness.

5.             Sector Overview

5.1.         India inflation hits record low, opening room for RBI rate cuts

India’s retail Consumer Price Index (CPI) inflation fell to a record low of 0.25 per cent (zero point two five per cent) in October 2025, according to Reuters on November 12, 2025, as sharp falls in food prices and recent cuts in Goods and Services Tax (GST) on mass-consumption items pulled headline inflation well below target. Food prices declined 5.02 per cent (five point zero two per cent) year-on-year, even as core inflation stayed around 4.4 per cent (four point four per cent) due to higher domestic gold prices. With inflation now below the RBI formal tolerance band of 2–6 per cent (two per cent to six per cent) for a second consecutive month, analysts expect a policy repo-rate cut of at least 25 (twenty-five) basis points in the December 2025 review and see scope for further easing in early 2026. For the Banking, Financial Services and Insurance (BFSI) sector, this creates expectations of lower lending and deposit rates, potential support for credit and capital markets, and the need for banks and other lenders to manage margin compression and interest-rate risk as the easing cycle progresses.

5.2.         RBI resumes bond purchases, easing yields and supporting liquidity

RBI has resumed secondary-market purchases of government bonds after a six-month pause, buying a net INR 12,470 crore (Indian Rupees Twelve Thousand Four Hundred Seventy Crore only) in the week ended November 7, 2025, based on central bank data reported by Reuters on November 14, 2025. These screen-based purchases, which followed the cancellation of a 7 (seven)-year bond auction due to weak demand, helped pull the 10 (ten)-year benchmark yield down by about 2 (two) basis points to around 6.51 per cent (six point five one per cent). Market participants expect such buying to continue and to be followed by formal Open Market Operation (OMO) auctions from December or January to fine-tune liquidity and anchor yields. Renewed RBI support in the bond market reduces mark-to-market volatility on investment portfolios, lowers longer-tenor funding costs and shapes loan-pricing, treasury and duration strategies across banks, non-banking lenders and fixed-income funds.

Disclaimer

The note is prepared for knowledge dissemination and does not constitute legal, financial or commercial advice. AK & Partners or its associates are not responsible for any action taken based on its contents.

For further queries or details, you may contact:

Mr Anuroop Omkar

Partner, AK & Partners

info@akandpartners.in