Complaint scope and exclusions: IO versus RBI Scheme

A commercial decision and a service failure associated with that decision must be distinguished.

Published by Finin2min · Updated 24 October 2026

How this provision works

Corporate fraud without any customer impact and suggestions/commercial decisions are listed IO exclusions, but the bank must still send rejected/partly resolved complaints in those two categories to the IO to examine whether an inherent service deficiency exists.
Staff administration, HR/pay disputes, judicial/quasi-judicial pending or decided matters and disputes with the specific CICRA section 18 remedy are separately excluded. A normal service complaint about credit information is not automatically the same thing as a section 18 dispute.
For the external RBI Scheme, apply its separate clause 10 conditions and exclusions, including same-grievance proceedings and commercial judgment. Criminal proceedings or a police investigation are expressly distinguished from a same-grievance court/tribunal bar.
Do not promise access to every RBI-regulated entity: external Scheme coverage and internal IO applicability are defined separately.

Practical illustration

A lender may decline a new loan on commercial credit judgment. An allegation that it charged an unauthorised fee or failed to correct a documented reporting error raises a different service question; analyse the actual deficiency rather than rejecting it solely under a broad “commercial decision” label.

The example is illustrative; it is not a reported company or court case.

Questions answered

Can the business unit conclusively exempt every commercial-decision complaint from IO review?

No. The stated rejected/partial categories still go to the IO to examine inherent service deficiency.

Does a police cyber-fraud investigation automatically bar a Scheme complaint?

No. Clause 10 distinguishes criminal proceedings and police investigation from the specified same-grievance judicial bar.

Primary source and edition

Commercial Banks Internal Ombudsman Directions 2026 and RB-IOS2026; separate NBFC and Credit Information Companies directions identified by actual title. Commercial Banks IO Directions 2026 clause 14(5); RB-IOS2026 clause 10(2).

Open the official instrument at this provision

Legal effect follows the instrument’s commencement and amendment provisions; a website upload date does not by itself change the law.

Related primary authorities

Scope and source editions

The public RBI Ombudsman Scheme 2026 applies from 1 July 2026, with the 2021 saving in clause 20. The internal-review explanation uses the Commercial Banks IO Directions of 14 January 2026 and compares specific NBFC/CIC differences where stated. Bank IO applicability generally requires 10 or more banking outlets at 31 March 2025, with a six-month rule for later qualification. NBFC internal-IO thresholds differ from external Scheme coverage. CIC source 13276 means Credit Information Companies; source 13274 means NBFCs and 13273 means Payments Banks.