Banking Law
RBI Integrated Ombudsman Scheme 2026: Complaints Against Banks
A customer with a grievance against a bank has always had a court. What he has rarely had is a remedy proportionate to the grievance, because the sums in dispute are usually small and the cost of litigation is not. The Ombudsman was created to close that gap: a free, informal, quick forum that the bank pays for and the customer does not. The integrated scheme launched in 2021 settled the central reform: the customer no longer has to work out which scheme covers his complaint, which office has jurisdiction, or whether his grievance fits a listed ground. The Reserve Bank Integrated Ombudsman Scheme, 2026, in force from 1 July 2026, keeps that design and tightens it, with a shorter filing window, higher compensation and screening of maintainability at the point of filing.
1. How the Scheme developed
The Integrated Ombudsman Scheme, 2021 was launched on 12 November 2021 and integrated three existing schemes into one. The Scheme of 2026, issued by the Reserve Bank in January 2026, came into force on 1 July 2026 and repealed the Scheme of 2021 from that date. Complaints received before 1 July 2026, appeals from decisions under the Scheme of 2021 and the execution of its awards continue to be governed by the Scheme of 2021.
Figure 1: From three schemes to one, and its revision
The integration is captured in the phrase one nation, one ombudsman, and it removed three distinct sources of difficulty for the complainant, each of which the Scheme of 2026 retains.
- No more choosing a scheme. Whether the entity complained against is a bank, a non-banking financial company, a non-bank prepaid instrument issuer or a credit information company, the same scheme applies. The complainant does not have to characterise his grievance before making it.
- No more territorial jurisdiction. Each Ombudsman office formerly had a defined area, and a complaint filed in the wrong office was returned. The Scheme is jurisdiction neutral, and complaints are allotted centrally.
- No more closed list of grounds. The earlier schemes listed the grounds on which a complaint could be made, and a grievance that did not fit the list was rejected however genuine it was. The Scheme replaces the list with a single concept, deficiency in service, subject to a list of exclusions.
⚠ Key point The shift from a list of inclusions to a list of exclusions is the single most important change. It reverses the default: everything is covered unless it has been taken out, rather than nothing being covered unless it has been put in. |
2. Who and what the Scheme covers
- The Scheme is framed under Section 35A of the Banking Regulation Act, 1949, Section 45L of the Reserve Bank of India Act, 1934, Section 18 of the Payment and Settlement Systems Act, 2007 and Section 11 of the Credit Information Companies (Regulation) Act, 2005.
- Regulated entities are commercial banks, regional rural banks, State and Central cooperative banks, scheduled primary (urban) cooperative banks, and non-scheduled primary (urban) cooperative banks with deposits of fifty crore rupees or more; non-banking financial companies that accept deposits, or that have a customer interface and assets of one hundred crore rupees or more, excluding specified categories such as housing finance companies, core investment companies and primary dealers; non-bank prepaid payment instrument issuers; and credit information companies.
- A complaint is a representation alleging deficiency in service, meaning a shortcoming or inadequacy in a service that the regulated entity provides or is required to provide, whether by statute or otherwise, which may or may not have resulted in financial loss to the customer.
- The service must be one within the regulatory purview of the Reserve Bank.
3. When a complaint is not maintainable
The Scheme of 2026 separates two things: the conditions every complaint must satisfy, and the matters excluded whatever the complaint says. Together they replace the old list of grounds.
The conditions of maintainability
- The complaint is addressed to the Ombudsman directly; merely copying the Reserve Bank on a complaint to the entity does not count.
- It is lodged personally or through an authorised representative other than an advocate, unless the advocate is himself the aggrieved person.
- It contains the complete information the Scheme requires, and is not abusive, frivolous or vexatious.
- The customer first complained to the regulated entity in writing or by another mode of which proof exists, and received no reply within thirty days (or any longer timeline prescribed by the Reserve Bank, the payment system operator or the card network), or is dissatisfied with the reply.
- The complaint is filed within ninety days of the later of the expiry of that period or the date of the entity's last communication.
- The same grievance is not pending before, or already decided on merits by, the Ombudsman's office, or any court, tribunal, arbitrator or other judicial or quasi-judicial forum. Criminal proceedings or a police investigation do not count as the same grievance for this purpose.
- The complaint to the entity was made before the expiry of the period of limitation prescribed by the Limitation Act, 1963.
The excluded matters
- A commercial judgment or decision of the regulated entity. Refusal of a loan, the rate offered, or the classification of an account are business decisions, not service failures.
- A dispute between a vendor and the entity.
- A general grievance against the management or the executives of the entity.
- An action taken in compliance with the orders of a judicial, quasi-judicial, statutory or law enforcing authority.
- A service not within the regulatory purview of the Reserve Bank.
- A dispute between regulated entities.
- A dispute involving the employee and employer relationship.
- A grievance for which Section 18 of the Credit Information Companies (Regulation) Act, 2005 provides a remedy.
- A grievance of customers of entities not covered by the Scheme.
⚠ Note The first exclusion does most of the work in practice. A customer unhappy that his loan was refused, or that the interest rate was raised, is complaining about a commercial judgment and will be turned away. A customer who was promised a rate and charged another, or whose application was simply never acted on, is complaining about service and will be heard. |
4. The route a complaint takes
Figure 2: From the branch counter to the Appellate Authority
- The entity first. The complainant must have made a written complaint to the regulated entity, or made it by another mode of which proof exists.
- Thirty days. The complaint may go to the Ombudsman if the entity has rejected it wholly or partly, has given an unsatisfactory reply, or has not replied within thirty days, or within any longer timeline prescribed for that kind of transaction.
- The time limit. The complaint must reach the Ombudsman within ninety days of the later of the expiry of that period or the entity's last communication. Under the Scheme of 2021 the period was one year from the reply, or one year and thirty days from the original complaint where there was none. The complaint to the entity must in any case have been made within the period of limitation under the Limitation Act, 1963.
- How it is filed. Online through the complaint management portal, by electronic mail, or in physical form to the Centralised Receipt and Processing Centre of the Reserve Bank at Chandigarh. A complaint filed on the portal is validated for maintainability at the outset, and one received by mail or post is screened by the Centre before registration. A toll free contact centre on 14448 assists complainants.
- Representation of the entity. Each regulated entity appoints a Principal Nodal Officer, who represents it and furnishes the information the Ombudsman requires.
- Reply or ex parte. The entity must file its written response and documents within fifteen days, which the Ombudsman may extend on a written request. If it does not, the Ombudsman may proceed ex parte on the record and pass an award.
- Conciliation first. The Ombudsman promotes a settlement by agreement, and may issue non-binding advisories at any stage to help the parties settle. Only if that fails does he pass an award or reject the complaint.
5. The award, and what it may contain
- There is no monetary ceiling on the dispute. The Ombudsman may entertain a complaint whatever the amount involved.
- The award may direct the entity to pay the amount in dispute, such as a sum wrongly debited, and in addition compensation for consequential loss of up to thirty lakh rupees.
- It may further award up to three lakh rupees for loss of time, expenses incurred, and harassment and mental anguish suffered. Under the Scheme of 2021 the two caps were twenty lakh rupees and one lakh rupees, and they continue to govern complaints received before 1 July 2026.
- It may direct specific performance, such as the correction of a credit record or the release of a security, and the Ombudsman may implead another regulated entity whose failure to follow the Reserve Bank's directions contributed to the deficiency.
- The award lapses unless the complainant furnishes, within thirty days of receiving a copy of the award, a letter accepting it in full and final settlement of his claim.
- The entity must comply with the award and report compliance, or prefer an appeal, within thirty days of receiving the complainant's letter of acceptance. Non-compliance is itself a supervisory matter for the Reserve Bank.
⚠ Key point The thirty lakh figure is the ceiling on consequential loss, not on the amount in dispute. A customer wrongly debited forty lakh rupees may be directed the whole of that debit back; what is capped is the compensation for what flowed from the deficiency. |
6. Appeal
An appeal lies to the Appellate Authority, who is the Executive Director in charge of the department of the Reserve Bank administering the Scheme, which is the Consumer Education and Protection Department.
- A complainant may appeal within thirty days of receiving the award, and the Appellate Authority may allow a further period of up to thirty days where sufficient cause for the delay is shown.
- A regulated entity may appeal only against the classes of award the Scheme makes appealable, within thirty days of receiving the complainant's letter of acceptance, with the same further period for sufficient cause, and only with the previous sanction of an Executive Director or an official of equal rank.
- The Appellate Authority may dismiss the appeal, allow it and set aside the award, remand the matter, modify the award, or pass any other just and equitable order.
7. What the Scheme is, and what it is not
- It is free. No fee is charged to the complainant at any stage.
- It is not a court. The Ombudsman is an officer of the Reserve Bank appointed under a Scheme framed under Section 35A of the Banking Regulation Act, 1949 and the corresponding provisions for other entities, not a judicial authority, and the proceedings are summary rather than adversarial. The Reserve Bank is now required to publish an annual report on the working of the Scheme.
- It is not exclusive. A complainant who is dissatisfied may go to a consumer commission or to a civil court, and a complaint already before such a forum is excluded from the Scheme only because of the bar on parallel proceedings, not because the Scheme ousts them.
- It does not decide complex questions of fraud, forgery or disputed title, which require evidence that a summary forum cannot take. The Scheme permits a complaint to be rejected at any stage where the evidence it needs is unsuited to the process, leaving the complainant to pursue the appropriate remedy.
8. Quick Revision
✦ The Scheme in numbers 12 November 2021: the integrated scheme launched, merging the schemes of 2006, 2018 and 2019. 1 July 2026: the Scheme of 2026 in force, with complaints received earlier still governed by the Scheme of 2021. One nation, one ombudsman: no choice of scheme, no territorial jurisdiction, no list of grounds. Deficiency in service: the single ground, subject to the conditions of maintainability and the excluded matters. Thirty days: to wait for the entity's reply, to accept the award, and to appeal. Ninety days: the time to file, replacing the one year period of the Scheme of 2021. Fifteen days: for the entity to reply, failing which the Ombudsman may proceed ex parte. Thirty lakh and three lakh: consequential loss, and loss of time, expenses and harassment, up from twenty lakh and one lakh. Chandigarh: the Centralised Receipt and Processing Centre. Executive Director in charge of consumer protection: the Appellate Authority, with a further thirty days for sufficient cause. |
- The complainant must approach the entity first and wait thirty days.
- There is no ceiling on the amount in dispute, only on the compensation.
- A commercial judgment of the entity is not a deficiency in service.
- A matter pending or decided by a court, tribunal, arbitrator or the Ombudsman's office is excluded, but a pending criminal case or police investigation is not.
- An advocate may not represent a complainant unless he is himself the aggrieved person.
- Conciliation precedes adjudication.
- The award lapses if the acceptance letter is not furnished within thirty days.
- A regulated entity needs the previous sanction of an Executive Director or an official of equal rank to appeal.
9. Frequently Asked Questions
What changed for complainants under the Ombudsman Scheme of 2026?
Four things. The time to file fell from one year to ninety days, counted from the later of the expiry of the entity's reply period or its last communication, so a complainant can no longer wait long after the entity has answered. Compensation rose to thirty lakh rupees for consequential loss and three lakh rupees for loss of time, expenses and harassment. Maintainability is now checked at the point of filing, by the portal for online complaints and by the Centralised Receipt and Processing Centre for the rest. And the Scheme states expressly that a pending criminal case or police investigation is not the same grievance, so a customer who has reported a fraud to the police may still complain about the entity's handling of it.
What changed most for a complainant in 2021?
The removal of the list of grounds. Under the earlier schemes a complaint had to fit one of the enumerated grounds, and a genuine grievance that fell outside them was rejected without being examined. The Scheme of 2021 replaced that with the single concept of deficiency in service and a list of exclusions, which the Scheme of 2026 retains, so the question is no longer whether the complaint is covered but whether it has been taken out. The second change is the removal of territorial jurisdiction: complaints go to one centre at Chandigarh and are allotted from there, so a complainant need not know which office covers the branch he is complaining about.
Can the Ombudsman decide a dispute about a forged signature?
Ordinarily not. The proceedings are summary: there is no examination in chief, no cross examination and no expert evidence of the kind a disputed signature requires. Where a complaint turns on allegations of fraud or forgery, or on a disputed question of title or of fact that cannot be decided on documents, the Ombudsman may reject it on the ground that the evidence required is unsuited to the process, and leave the complainant to the civil court. The same limitation applies to consumer commissions, and for the same reason. What the Ombudsman can decide is whether the bank's own process was deficient, which is often the real grievance.
Does accepting an award prevent the customer from suing?
Yes, to the extent of that claim. The award lapses unless the complainant furnishes, within thirty days of receiving it, a letter accepting it in full and final settlement of his claim. The acceptance is therefore a settlement, and the complainant cannot accept the money and then sue for more on the same cause of action. A complainant who thinks the award inadequate has two choices: appeal to the Appellate Authority within thirty days, or decline the award and pursue his remedy in a consumer commission or a civil court.
Why can an advocate not appear for a complainant?
Because the Scheme is designed as an informal, free and non-adversarial process in which an individual customer is not supposed to need representation, and in which the regulated entity is not permitted to use its greater resources to outmatch him. The bar is on representation, not on advice, so a complainant may take legal advice in preparing his complaint. The exception in the Scheme is narrow and sensible: an advocate may appear where he is himself the aggrieved person, since to hold otherwise would be to exclude an entire profession from the remedy.
Is the Ombudsman's award binding on the bank?
It binds the entity once the complainant accepts it in full and final settlement within thirty days. The entity must then comply within thirty days of receiving the acceptance unless it appeals, and where it appeals the award binds if the appeal fails. The Scheme is framed by the Reserve Bank under its statutory powers of direction, and non-compliance with an award is therefore not merely a private default but a supervisory failure that the Reserve Bank may act on. In practice that is a stronger sanction than a decree, because a regulated entity has far more to lose from an adverse supervisory record than from the sum in dispute.
How does the 2026 Scheme deal with a complaint the bank has not answered?
A complaint is maintainable once the customer has complained in writing to the regulated entity and either received no reply within 30 days, or been rejected wholly or partly, or remains dissatisfied, provided the complaint reaches the Ombudsman within 90 days of that reply or of the 30 day period expiring. The Scheme therefore forces the bank's internal grievance machinery to act first, and the internal ombudsman must review rejections before they go out. For the customer the practical rule is to complain in writing, keep the acknowledgment, and file with the Ombudsman as soon as the 30 days pass without a satisfactory answer. A complaint filed too early is not rejected on the merits; it is treated as not maintainable and can be filed again once the condition is met. The 90 day clock makes delay the greater danger, and the portal records the date of the entity's reply, so the sequence is checked mechanically at the filing stage.
10. Related Topics and Provisions
- Banking and the Consumer Protection Act, 2019
- Electronic banking and customer liability for unauthorised transactions
- The duties of a banker: secrecy, care and honouring cheques
- The Payment and Settlement Systems Act, 2007
- Inspection, supervision and penalties under the Banking Regulation Act, 1949
- Nature of the banker and customer relationship