AKP Banking & Finance Digest November 24, 2025

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1. Regulatory Updates

1.1.  India

Reserve Bank of India (RBI)

1.1.1. RBI updates Alert List of unauthorised online forex trading platforms

Reserve Bank of India (“RBI”) has issued a press release dated November 19, 2025, updating its Alert List of unauthorised forex trading platforms by adding 7 (seven) entities, namely Starnet FX, CapPlace, Mirrox, Fusion Markets, Trive, NXG Markets and Nord FX, and has published the revised list on its website for public information. The Alert List flags online platforms and websites that are not authorised to deal in foreign exchange under Indian law and is intended to help individuals and corporates avoid engaging with unregulated providers when undertaking foreign exchange transactions.

1.1.2. RBI amends Foreign Exchange Management (Export of Goods and Services) Regulations, 2015

RBI has notified the Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025, amending the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015 to relax key timelines for export transactions. The period within which exporters must realise and repatriate the full value of goods or services has been increased from 9 (nine) months to 15 (fifteen) months, including for cases where goods are held on consignment basis abroad. At the same time, the time limit for authorised dealers and exporters to write off unrealised export bills and related export dues has been extended from 1 (one) year to 3 (three) years, thereby providing greater operational flexibility while retaining the obligation to bring export proceeds into India within a defined outer limit from the date of publication of the amendment in the Official Gazette, which is November 13, 2025.

1.1.3. RBI and European Central Bank advance UPI–TIPS link for cross-border payments

RBI announced that it has agreed with the European Central Bank (“ECB”) to begin the “realisation phase” for interlinking India’s Unified Payments Interface (“UPI”) with the TARGET Instant Payment Settlement (“TIPS”) system of the Eurosystem, following sustained engagement by RBI and NPCI International Payments Limited (“NIPL”). The proposed UPI–TIPS link, aligned with the Group of Twenty (G20) Roadmap on enhancing cross-border payments, is intended to make remittances between India and the Euro Area cheaper, faster, more transparent and more accessible for users in both jurisdictions. RBI and NIPL will continue working with ECB on technical integration, risk management and settlement arrangements to operationalise the corridor and support more efficient retail cross-border transfers.

Securities and Exchange Board of India (SEBI)

1.1.4.  SEBI cautions investors against unregistered online bond platforms

Securities and Exchange Board of India (“SEBI”) has issued a press release warning that certain entities, including fintech companies and stockbrokers, are acting as Online Bond Platform Providers (“OBPPs”) without obtaining the mandatory registration from stock exchanges as required under its November 2022 framework, and that such unregistered platforms operate without regulatory oversight, investor protection mechanisms or grievance redressal. SEBI has cautioned that activities of these unregistered platforms may violate the Companies Act, 2013 and the SEBI Act, 1992, and has reminded investors to avoid transacting on unregistered online bond platforms, to verify the registration status of OBPPs using the lists hosted on the SEBI, National Stock Exchange (NSE) and Bombay Stock Exchange (BSE) websites, and to deal only with SEBI-registered entities. All market participants have also been urged to ensure full compliance with the applicable OBPP regulatory framework before offering any such services.

1.1.5. SEBI notifies Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) (Fifth Amendment) Regulations, 2025

SEBI has notified the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) (Fifth Amendment) Regulations, 2025, which refine the treatment of related party transactions, clarify annual report disclosures and adjust requirements for holders of non-convertible securities. The amendment expands the exemption language in the related party framework to cover directors, key managerial personnel and their relatives of the listed entity and its subsidiaries and replaces the earlier single threshold for “material” related party transactions with a new slab-based regime in Schedule XII that links limits to consolidated turnover and caps them at INR 5,000 Crore (Indian Rupees Five Thousand Crores only). It also tightens rules for transactions undertaken solely at the subsidiary level by requiring prior approval of the listed entity’s audit committee once specified value thresholds, based on either turnover or paid-up capital and securities premium, are crossed, and clarifies that omnibus shareholder approvals for material related party transactions obtained in annual general meetings remain valid only until the next such meeting or for a maximum of 1 (one) year if granted in any other general meeting.

1.1.6. SEBI issues extension of timeline for submission of public comments on the consultation paper on 'Comprehensive review of SEBI (Mutual Funds) regulations, 1996

SEBI has extended the last date for submitting public comments on its consultation paper on “Comprehensive review of SEBI (Mutual Funds) Regulations, 1996” from November 17, 2025, to November 24, 2025. The consultation paper was published on October 28, 2025, and stakeholders are required to submit their comments or suggestions through the web-based public comments form available on the SEBI website at the specified link. In case of any technical difficulty in using the online form, comments may instead be sent by e-mail to Deputy General Manager Peter Mardi or Manager Gopika Jayan with the subject line “Consultation paper on comprehensive review of SEBI (Mutual Funds) Regulations, 1996”, ensuring that feedback reaches SEBI by the revised deadline.

International Financial Services Centres Authority (IFSCA)

1.1.7. IFSCA mandates AML/CFT certification for Designated Directors and Principal Officers in IFSC

International Financial Services Centres Authority (“IFSCA”) has issued a circular dated November 17, 2025 directing that all Designated Directors and Principal Officers of Regulated Entities (“REs”) in the International Financial Services Centre (“IFSC”) must mandatorily complete and continually hold the NISM-IFSCA-01 Certification Course on Anti-Money Laundering and Countering the Financing of Terrorism (“AML/CFT”), which is aligned with the IFSCA Anti-Money Laundering, Counter-Terrorist Financing and Know Your Customer (“KYC”) Guidelines, 2022 and is being launched on November 18, 2025. The circular requires these key functionaries to complete the course within 4 (four) months from the launch date or from their appointment, whichever is later, while encouraging other employees also to undergo the programme and obliging REs to ensure ongoing capacity-building for front-line and relevant staff. Issued under the International Financial Services Centres Authority Act, 2019 and the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005, the move reinforces IFSCA’s focus on strengthening governance and compliance standards for AML/CFT and KYC in the IFSC.

1.1.8. IFSCA issues Consultation Paper on proposed amendment to IFSCA (Registration of Insurance Business) (Amendment) Regulations, 2025

IFSCA has issued a consultation paper on the proposed International Financial Services Centres Authority (Registration of Insurance Business) (Amendment) Regulations, 2025 to revise the definition of “Service Companies of Lloyd’s IFSC” in the existing 2021 framework. The draft amendment, prepared after a representation from Lloyd’s London, seeks to expand the list of eligible promoters so that Service Companies registered in the IFSC may be promoted not only by Managing Agents of Lloyd’s but also by their group entities or Members of Lloyd’s, as permitted by Lloyd’s, alongside Indian companies that meet specified criteria, instead of the current position where only Managing Agents of Lloyd’s or an Indian company can establish such entities. The draft regulations have been placed on the IFSCA website, and general public and stakeholders have been invited to submit comments in Microsoft Word or Microsoft Excel format by November 29, 2025, to the Insurance Department through the designated e-mail addresses.

Miscellaneous

Ministry of Electronics and Information Technology (MeitY)

1.1.9. MeitY re-notifies Designated Officer for blocking orders under IT Act

Ministry of Electronics and Information Technology (MeitY) has issued a fresh notification under the Information Technology Act, 2000 read with the Information Technology (Procedure and Safeguards for Blocking for Access of Information by Public) Rules, 2009, superseding its earlier notification of October 21, 2025, and reconstituting the authority responsible for issuing blocking directions. The Central Government has designated Akhil Kumar, Managing Director and Chief Executive Officer of Digital India Corporation in the rank of Additional Secretary to the Government of India, as the Designated Officer for the purposes of the Blocking Rules, and has further designated Joint Secretary Sushil Pal as the Designated Officer during periods when Akhil Kumar is on leave, tour or otherwise unavailable, thereby formalising the chain of responsibility for processing and issuing blocking orders.

Telecom Regulatory Authority of India (TRAI)

1.1.10.  TRAI mandates phased adoption of 1600-series calling numbers by BFSI entities

Telecom Regulatory Authority of India (“TRAI”) has issued a Direction, supported by a press release, mandating a phase-wise and time-bound adoption of the 1600 (one thousand six hundred)-series telephone numbers for service and transactional voice calls made by entities in the Banking, Financial Services and Insurance (“BFSI”) sector regulated by the RBI, SEBI and Pension Fund Regulatory and Development Authority (PFRDA), following allocation of this special series by the Department of Telecommunications (“DoT”). The framework requires commercial banks, non-banking financial companies, payment banks, small finance banks, mutual funds, asset management companies, Qualified Stockbrokers (QSBs), Central Recordkeeping Agencies and pension fund managers to migrate from ordinary mobile numbers to 1600-series numbers under a staggered schedule running from January 1, 2026, to March 15, 2026, while other SEBI-registered intermediaries may voluntarily adopt the series.

1.1.11.  TRAI refines its proposed DEPA-based framework for consent-driven telecom KYC data sharing

TRAI issued its response to the DoT reaffirming and refining earlier recommendations for a consent-based framework to share telecom subscriber Know Your Customer (“KYC”) data. TRAI addresses DoT’s concerns about possible conflict with existing Mobile Number Portability (MNP) regulations and ongoing demographic-matching pilots, clarifying that electronic validation via the Digital Intelligence Unit (DIU) and a Mobile Number Validation (MNV) platform can prevent fraudulent porting without directly exchanging customer application forms between operators. Drawing on new provisions under the Telecommunications Act, 2023, the Telecommunications Cyber-security (Amendment) Rules, 2025 and the draft Telecommunications (Authorisation for Provision of Main Telecommunication Services) Rules, 2025, which permit consent-based use of user information, TRAI revised its recommendation to seek a government-backed Data Empowerment and Protection Architecture (DEPA) style framework for consent-based sharing or validation of telecom KYC data, including during number portability.

Monetary Penalties

1.1.12.  RBI imposes penalties on four 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 Big Kancheepuram Co-operative Town Bank Limited, Tamil Nadu	INR 50,000 (India 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.
2.	Shri Basaveshwar Sahakari Bank Niyamitha, Bagalkot, Karnataka	INR 1,00,000 (Indian Rupees One Lakh only)	Non-compliance with certain directions issued by RBI on 'Income Recognition, Asset Classification, Provisioning and Other Related Matters – UCBs' and 'Reserve Bank of India (Co-operative Banks - Interest Rate on Deposits) Directions, 2016'. 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 Nawada Central Co-operative Bank Limited, Bihar	INR 1,50,000 (Indian Rupees One Lakh Fifty Thousand only)	Contravention of provisions of Section 26A read with Section 56 of the Banking Regulation Act, 1949 (BR Act) and non-compliance with certain directions issued by RBI on ‘Membership of Credit Information Companies by Co-operative Banks’. 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 BR Act and Section 25 read with Section 23 of the Credit Information Companies (Regulation) Act, 2005.
4.	Glowmore Finance Private Limited, Odisha	INR 4,00,000 (Rupees Four Lakh only)	Non-compliance with certain provisions of the ‘Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023’ issued by RBI. This penalty has been imposed in exercise of powers conferred on RBI under clause (b) of sub-section (1) of Section 58G read with clause (aa) of sub-section (5) of Section 58B of the Reserve Bank of India Act, 1934.

2.  Key Asian Markets - Philippines and Indonesia

2.1. Philippines

2.2.1. BSP reports cash and personal remittance increase in September

Cash remittances from Overseas Filipinos (OF) increased by 3.7 per cent (three point seven per cent) year-on-year in September 2025. They rose from USD 3.01 billion (United States Dollar Three Billion and Ten Million only) in September 2024 to USD 3.12 billion (United States Dollar Three Billion One Hundred and Twenty Million only). On a cumulative basis, cash remittances for January to September 2025 grew by 3.2 per cent (three point two per cent) from USD 25.23 billion (United States Dollar Twenty-five Billion Two Hundred and Thirty Million only) to USD 26.03 billion (United States Dollar Twenty-six Billion and Thirty Million only). The United States remained the largest source of remittances to the Philippines during this period, followed by Singapore and Saudi Arabia. Personal remittances, which include cash sent through banks, informal channels and remittances in kind, rose by 3.8 per cent (three point eight per cent) from USD 3.34 billion (United States Dollar Three Billion Three Hundred and Forty Million only) in September 2024 to USD 3.46 billion (United States Dollar Three Billion Four Hundred and Sixty Million only) in September 2025, while year-to-date personal remittances increased by 3.2 per cent (three point two per cent) from USD 28.07 billion (United States Dollar Twenty-eight Billion Seventy Million only) to USD 28.97 billion (United States Dollar Twenty-eight Billion Nine Hundred and Seventy Million only) over the same period.

2.2.2. BSP posts USD 706 million balance of payments surplus as reserves rise

Philippines’ balance of payments (“BOP”) registered a surplus of USD 706 million (United States Dollar Seven Hundred and Six Million only) in October 2025, reflecting improved external accounts even though the BOP for January to October 2025 still showed an overall deficit of USD 4.6 billion (United States Dollar Four Billion Six Hundred Million only), which has begun to narrow as inflows strengthened. The monthly surplus was accompanied by an increase in gross international reserves (“GIR”) to USD 110.2 billion (United States Dollar One Hundred and Ten Billion Two Hundred Million only) as at end-October 2025, a level assessed as an adequate external liquidity buffer equivalent to 7.4 (seven point four) months of imports of goods and payments of services and primary income and covering about 3.8 (three point eight) times the country’s short-term external debt based on residual maturity. The BOP, which records the Philippines’ transactions with the rest of the world, and the GIR, which comprise foreign-denominated securities, foreign exchange and other assets including gold, together help the country finance imports and foreign debt obligations, stabilise the currency and cushion the economy against external shocks.

2.3. Indonesia

2.3.1. BI reports external debt decline as debt-to-GDP position strengthens

Indonesia’s external debt fell in the third quarter of 2025 to USD 424.4 billion (United States Dollar Four Hundred Twenty-four Billion Four Hundred Million only) from USD 432.3 billion (United States Dollar Four Hundred Thirty-two Billion Three Hundred Million only) in the previous quarter, marking a 0.6 per cent (zero point six per cent) annual contraction after 4.6 per cent (four point six per cent) growth earlier in the year. Government external debt rose at a slower pace to USD 210.1 billion (United States Dollar Two Hundred Ten Billion One Hundred Million only), reflecting weaker foreign capital inflows into government securities.

2.3.2. Indonesia’s BOP remains resilient with current account surplus and strong reserves

BI reported that Indonesia’s BOP remained sound in the third quarter of 2025, with the current account swinging to a surplus of USD 4 billion (United States Dollar Four Billion only), supported by higher non-oil and gas exports and a narrower services deficit as inbound tourism increased, even though the overall BOP still recorded a deficit of USD 6.4 billion (United States Dollar Six Billion Four Hundred Million only). Foreign exchange reserve assets stayed robust at USD 148.7 billion (United States Dollar One Hundred and Forty-eight Billion Seven Hundred Million only), equivalent to about 6.0 (six point zero) months of imports and servicing government external debt, comfortably above the international adequacy norm of around 3 (three) months. The capital and financial account deficit was assessed as manageable, with direct investment continuing to register a surplus that reflected investor confidence in Indonesia’s economic prospects, while portfolio and other investments posted deficits amid regional capital outflows and higher private sector external debt, partially offset by lower public sector external debt repayments and increased foreign currency (FX) assets of banks.

3. Trends

3.1. PMO to weigh major PSB reforms, including mergers and FDI cap hike

The Prime Minister’s Office (“PMO”) is reported to be preparing a meeting to review a reform blueprint for India’s public sector banks (“PSBs”) ahead of the Union Budget for financial year 2026–2027, a move that could reshape the Banking, Financial Services and Insurance (BFSI) sector if the ideas are accepted. According to government sources, the Department of Financial Services has proposed a fresh phase of PSB consolidation, greater operational autonomy for PSB boards and a phased increase in the foreign direct investment (FDI) ceiling in PSBs from 20 per cent (twenty per cent) to 49 per cent (forty-nine per cent), along with a possible revival of earlier plans to privatise select state-owned lenders. These measures are currently only options to be discussed at the PMO meeting set out in the media coverage, so markets are treating them as policy scenarios rather than decisions that have been cleared by the government.

3.2. Speculation over IndusInd Bank QIP ‘confidence capital’ raise remains unresolved

IndusInd Bank may be in the early stages of exploring a qualified institutional placement (“QIP”) share sale to raise so-called “confidence capital” after accounting discrepancies in its foreign-exchange derivatives book and related senior-level exits, with senior management said to be meeting potential global investors. However, the same coverage notes that the bank has told journalists and stock exchanges that it is well capitalised, has cleaned up its books and “categorically” denied that it is engaged in board-approved discussions on such an equity raise, describing queries on a QIP as speculative and factually inaccurate, so for now the possibility of a future capital-raising transaction remains an unconfirmed market narrative rather than a concrete plan.

4. Sector Overview

4.1. Foreign-exchange reserves jump on gold valuation gains, strengthening external buffers

India’s foreign-exchange reserves rose by USD 5.54 (five point five four) billion in the week ended November 14, 2025, taking the total stockpile to USD 692.58 (six hundred ninety-two point five eight) billion according to Reserve Bank of India data, with the bulk of the increase driven by a sizeable mark-to-market gain of about USD 5.33 (five point three three) billion on the central bank’s gold holdings and smaller improvements in foreign-currency assets, Special Drawing Rights and the reserve position with the International Monetary Fund; coming after a USD 2.70 (two point seven zero) billion decline in the previous week, the rebound further strengthens India’s external shock-absorption capacity, supports the Indian Rupee and gives the monetary authority more room to manage capital-flow volatility and any portfolio-flow shifts that could accompany prospective policy rate cuts or global risk-off episodes, developments that are closely tracked by banks, non-bank lenders and capital-market participants.

4.2. SBI research flags near 7.5–8 per cent Q2 growth on GST boost and festive demand

State Bank of India’s Ecowrap research unit now projects India’s July–September quarter real gross domestic product growth at about 7.5 (seven point five) to 8 (eight) per cent, arguing that the recent Goods and Services Tax (“GST”) rate cuts, strong festive-season consumption and improving rural momentum are together lifting activity, and estimating that November 2025 GST revenues could cross INR 2,00,000 (Indian Rupees Two Lakhs) crore, with gross domestic GST collections of roughly INR 1,49,000 (Indian Rupees One Lakh Forty-Nine Thousand) crore and a 6.8 per cent (six point eight per cent) year-on-year increase once about INR 51,000 (Indian Rupees Fifty-One Thousand) crore of Integrated GST and import-linked cess are added; for the Banking, Financial Services and Insurance sector this combination of strong tax buoyancy, above-trend real growth and very low inflation is being read as supportive for credit demand while simultaneously intensifying the policy debate over when the RBI should begin an interest-rate easing cycle.

5. Business Updates

5.1. BlackSoil Capital–Caspian Debt merger creates larger tech-enabled SME and impact lender

The merger of alternative credit platform BlackSoil Capital and impact-focused lender Caspian Debt has been completed following approvals from the National Company Law Tribunal, Mumbai Bench, and the RBI. Effective November 1, 2025, the combined Non-Banking Financial Company (NBFC) operates as BlackSoil Capital Private Limited with assets under management of around INR 1,900 crore (Indian Rupees One Thousand Nine Hundred crore only) and cumulative disbursements of nearly INR 14,000 crore (Indian Rupees Fourteen Thousand crore only) across about 550 (five hundred fifty) companies, positioning it among India’s larger specialised lenders to small and medium enterprises and impact businesses; the integration also brings Caspian’s tech-led underwriting, loan-origination and early-warning systems into BlackSoil’s platform, alongside an expanded physical footprint across Mumbai, Hyderabad, Delhi, Gurgaon and Bengaluru.

5.2. State Bank of India signs term sheet to acquire up to 9.90 per cent stake in CareEdge Global IFSC Limited

State Bank of India (“SBI”) disclosed that it has entered into a non-binding term sheet with Care Ratings Limited to acquire 29,70,000 (twenty-nine lakh seventy thousand) equity shares of CareEdge Global IFSC Limited, representing up to 9.90 per cent (nine point nine zero per cent) of its equity share capital, with the proposed transaction contingent on execution of a definitive agreement and customary approvals; as reported by Angel One, the move is intended to deepen strategic collaboration in financial services at a time when SBI’s market capitalisation has recently crossed about INR 9 (nine) trillion, underscoring investor confidence in the bank’s growth trajectory.

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