India: India’s lenders have long judged their collections operations by how much overdue money came back. From 1 January 2027, the Reserve Bank of India will also want to see how it came back. RBI’s new recovery directions turn every call, visit, notice and settlement into something a lender may have to evidence. Here are five signs a collections stack is not ready for that.
1. No one can see a borrower’s full history in one place
The amendments to RBI’s Responsible Business Conduct Directions, issued on 6 August 2026, require lenders to:
● record recovery calls and keep the recordings for six months
● publish an up-to-date list of empanelled recovery agencies
● use only agents certified by the Indian Institute of Banking and Finance
Lenders also remain accountable for how outsourced agents behave.
Meeting those requirements is difficult when collections run on a patchwork of systems. Many lenders use one tool for SMS and WhatsApp reminders, another for the calling floor, a field app for visits and an outside vendor for legal notices. Call recordings sit in the dialer, visit notes in the field app and notices with the vendor. Piecing together a single borrower’s history for an audit or a complaint becomes a manual exercise.
Mumbai-based Mobicule Technologies has built its debt collections platform, mCollect, with an all-in-one integrated approach. Digital outreach, the contact centre, field collections and legal workflows run on one shared data layer. Every interaction is logged against the borrower’s account, and a case can move from a reminder to a call to a field visit without leaving the system.
2. The rules live in training material, not in the software
The directions limit recovery contact to between 8 am and 7 pm, bar repeated calls and require a day’s notice before a first physical visit. Collections floors and field teams tend to have high staff turnover, and training alone rarely holds every agent to every rule, every time.
The more dependable approach is to have the system enforce the rules: block calls outside permitted hours, check do-not-disturb status before dialling and log every attempt. Mobicule says mCollect builds RBI, TRAI, and Digital Personal Data Protection Act (DPDPA) requirements into its workflows through automated DND checks, mandatory audit logs, and full call recording.
Because rules and practices differ across banks, NBFCs, microfinance institutions and gold loan lenders, the company configures its workflows by lending segment rather than offering a single template.
3. A field visit is just a line in a spreadsheet
An entry reading “visited, customer not available” tells an auditor very little. Under the new rules, agents must carry identification and an authorisation letter and hold IIBF certification. Lenders must show who visited a borrower, where and when, and that the person was authorised to be there.
Field apps that verify the agent at login and geo-tag each visit close much of that gap. mCollect’s field app uses liveness-based face verification and GPS tagging. It also offers vernacular, offline-first versions for agents working in areas with patchy connectivity, which matters as lending grows beyond India’s top cities.
4. Notices go out, but proof of delivery does not come back
Lenders send Section 138 notices, SARFAESI notices and Lok Adalat communications in large volumes. Procedural gaps in these dispatches often surface months later, before a tribunal, when they are hardest to fix.
Courts have accepted demand notices sent by email and WhatsApp in cheque bounce cases. Even so, a lender must show that a notice was sent, to whom, and that it was delivered. Some platforms now combine digital and physical dispatch to cover both.
Mobicule’s “phygital” legal notice module generates notices in bulk, in multiple languages, handles postal dispatch and tracks last-mile delivery in real time. The company says this produces court-ready proof of delivery, linked to the account’s digital record. Its legal workflows for SARFAESI, Section 138, Lok Adalat and arbitration run within the same platform.
5. Settlements are negotiated off the books
The directions ask lenders to document how they engaged a borrower in financial distress before escalating a case. When waivers, settlement offers, and restructuring discussions happen over email, phone or at a branch, that trail is often scattered or missing.
Lenders are increasingly moving these conversations onto digital settlement workflows with built-in approval controls, and several public sector banks already run online one-time settlement portals. mCollect includes an e-OTS workflow with maker-checker validation, so each waiver carries an approval trail.
It also automates routine early-stage reminders, including AI voicebots, so trained human agents can focus on conversations that need judgement.
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