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FININ2MIN
Banking, UPI & Loan Disputes · 06/25

Credit Card Unauthorised Transaction: RBI Liability Rules in Plain English

Reviewed by CA Nikhil Gupta · Last reviewed 30 May 2026

A plain-English evidence framework for card fraud, reporting delay, customer negligence, bank deficiency, shadow reversal and final resolution.

Customer liability is not decided by a call-centre phrase such as ‘OTP was used.’ The cause, reporting time and evidence must be examined.

Classify

RBI’s framework provides zero liability in specified bank-deficiency and timely third-party-breach situations.

Evidence

Where loss is due to customer negligence, such as sharing payment credentials, the customer generally bears the loss until reporting; loss after reporting is borne by the bank.

Risk

Banks must provide round-the-clock reporting channels and acknowledge the complaint.

Escalation

The framework requires a shadow reversal within ten working days of notification and resolution within ninety days, subject to the circular.

What the customer or business should understand

The five-point review

CheckWhat to examine
TransactionMerchant, channel, amount, date and authentication.
CauseBank deficiency, third-party breach or customer negligence.
NoticeWhen the customer received alert, noticed and reported.
ContainmentCard block, token removal and credential reset.
DecisionProvisional credit, investigation evidence and final liability.

Practical example

A cardholder reports an overseas online purchase two hours after the SMS alert. The bank rejects it solely because an OTP appears in its system. The bank should still examine device, merchant, authentication and customer evidence under the RBI framework.

How to apply the framework

Ask the issuer to identify the precise liability category and evidence relied upon. Preserve call recordings or written responses where available.

Check whether card tokens, add-on cards, recurring mandates or compromised email accounts remain active after the card is blocked.

Dispute workflow

Classify the problem before choosing the remedy

Identify the regulated entity, transaction or loan account, date, amount, contractual document and exact failure. Review transaction, cause and notice together. A failed transaction, authorised mistake, unauthorised fraud, merchant dispute, credit-report error and lawful account freeze require different remedies.

Create one written chronology

Record the event, alert, discovery, first report, complaint number, response and financial impact in date order. Attach only the documents that prove each step. Phone calls can stop urgent harm, but a written acknowledgement creates the escalation record.

Escalate to the correct authority

Start with the bank, card issuer, lender, credit institution, app or other regulated entity responsible for the service. Use cybercrime or law-enforcement channels for suspected fraud. Use RBI CMS only after the regulated entity process satisfies the Scheme’s timing or rejection condition and the issue is within Ombudsman scope.

Implementation checkpoint

Before treating the case as closed, verify the actual bank statement, loan ledger, credit report, account status or merchant refund rather than relying only on a ticket message. Record who confirmed the financial outcome, the date, remaining open amount and the next escalation deadline. This final check prevents a complaint from being marked resolved while the money, lien, overdue status or credit record remains unchanged.

Action checklist

Evidence to keep

Warning signs

  • Waiting for statement generation
  • Calling only the merchant
  • Assuming OTP proves negligence
  • No written complaint
  • Destroying the device evidence

Finin2min takeaway

Banking disputes are resolved through classification, speed, written evidence and the correct escalation route. No legitimate bank, regulator or recovery process requires disclosure of an OTP, UPI PIN or remote-control access.

Frequently asked questions

Is customer liability always zero?

No.

Who proves customer liability?

The bank under the RBI circular.

When should the bank shadow-reverse?

Within ten working days of notification under the framework.

How long is the resolution period?

The circular provides up to ninety days.

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Disclaimer: This article is for education and general awareness. It is not legal, banking, lending, debt-settlement, investment, credit-repair, cyber-forensic or regulatory advice. Recovery, refund, liability, compensation, unfreezing, restructuring, auction and credit-report outcomes depend on facts, contracts, reporting time, evidence, the regulated entity and the competent authority. Use official channels and obtain advice from appropriately qualified professionals before acting.
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