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Effective 1 April 2026, the Reserve Bank of India's revised current account framework introduces
exposure-based restrictions that fundamentally change how banks manage current accounts for borrowers
with significant banking relationships. The changes tighten how banks track fund flows, clamp down on
circular transactions, and enforce credit discipline — with mandatory bi-annual reviews and RBI-auditable
compliance records for every eligible account.
The Core Rule
For any borrower with total banking exposure of Rs 10 crore or more, only a bank holding at least a 10% share of the total loan exposure across the banking system may operate that borrower's Current Account or Cash Credit/Overdraft (CC/OD) facility. Banks that do not meet this threshold cannot open or operate such accounts — regardless of the customer relationship.
The Tiered Exposure Framework
Tier 1 — Below Rs 10 Crore (Light-Touch Regime)
Borrowers with total banking system exposure below Rs 10 crore may open and operate current accounts freely with any bank. No additional checks, exposure calculations, or eligibility verifications are required. This exemption ensures SMEs face no additional compliance friction.
Tier 2 — Rs 10 Crore and Above (Exposure-Based Eligibility)
Banks must verify their share of total banking exposure against CRILC data before opening any current account or CC/OD facility. Only banks meeting the 10% minimum share threshold are eligible. This requires real-time CRILC data integration with the account opening system.
The Bi-Annual Review Mandate
Trigger / Event | Requirement | Deadline |
1 April 2026 | Framework in force — no new ineligible current accounts | Immediate |
Every 6 months | Mandatory eligibility review of all relevant borrower accounts | Ongoing |
Breach discovered | Immediate internal supervisory action; formal notice to borrower within 30 days | 30 days max |
Each review | Full audit trail of eligibility decisions and outcomes — RBI-inspectable | Ongoing |
Bank Systems and Reports Impacted
System | Required Change | Urgency |
Core Banking System (CBS) | Account opening eligibility engine: enforce 10% exposure threshold check; CRILC API integration; FEMA-exempt account flagging | Now |
Credit Risk / Limit System | Real-time exposure share calculation; CRILC data consumption; multi-bank consortium share tracking; threshold breach alerts | Now |
Bi-Annual Review Scheduler (NEW) | Automated review workflow: identify eligible accounts, schedule reviews, capture outcomes, maintain audit log | Now |
Compliance / Internal Audit Reports | New report: eligibility decisions, breach notices issued, supervisory actions — full audit trail for RBI inspection | Now |
CRILC Reporting Integration | Bidirectional data flow: existing CRILC submission also feeds internal eligibility engine in real-time | Now |