What changed
The Reserve Bank issued the Reserve Bank of India (Commercial Banks – Responsible Business Conduct) Second Amendment Directions, 2026 (RBI/2026-27/115) on 15 June 2026, effective 1 January 2027.
Clause 85V: "A bank shall not resort to compulsory bundling of any TPPS with any of its own product / service." Where the bank's own product is contingent on a third-party product as a risk mitigant, "the customer shall be provided the option to purchase the same from any TPPS Provider". A package taken on voluntary consent is not compulsory bundling.
A dark pattern is defined as design "designed to mislead or trick users to do something they originally did not intend or want to do"; clause 85X subjects user interfaces to "user testing and periodic internal audit".
Consent must be explicit — a signed declaration, OTP approval or digitally recorded confirmation — and on digital interfaces "the default choice … shall be 'No' / 'I do not agree'". Where mis-selling is established the bank "shall refund the entire amount paid by the customer" and compensate for loss under its approved policy, on a complaint within 30 days of receiving the signed agreement.
RBI's 11 February 2026 drafts had proposed a 1 July 2026 start.
Who is affected
Commercial banks other than Small Finance Banks, Payments Banks, Regional Rural Banks and Local Area Banks — the scope the directions name; Small Finance Banks got parallel directions the same day (RBI/2026-27/116). Nothing changes before 1 January 2027: pre-ticked add-ons and insurance attached at the point of sale stay legal until then.
What to do
Until then the burden is yours: decide on published terms, not the application flow. HDFC Bank Infinia charges ₹12,500 a year and waives renewal at ₹10 lakh of spend — ₹83,333 a month. Axis Bank Magnus charges the same ₹12,500 but waives at ₹25 lakh, or ₹2,08,333 a month: two and a half times the spend for the same relief. Both verified 11 June 2026; HDFC Infinia vs Axis Magnus and our methodology show the working.
Know the fee before the add-ons: our credit card fees in India, explained guide lists every charge an Indian card can levy, and the annual fee waiver guide covers spend conditions. A bundled product is easiest to refuse when you know what the card costs without it.
Sources
- RBI — Reserve Bank of India (Commercial Banks – Responsible Business Conduct) Second Amendment Directions, 2026 (RBI/2026-27/115) — 15 June 2026
- RBI — Draft Directions: Responsible Business Conduct Amendment Directions, 2026 — 11 February 2026
- RBI — Statement on Developmental and Regulatory Policies — 6 February 2026