Chapter III — Central Banking Functions
Section 22A: Non-applicability of certain provisions to digital form of bank notes
Reviewed by CA Nikhil Gupta · Last reviewed 18 September 2026
Section 22A is a direct statutory carve-out for bank notes in digital form issued by RBI.
Finin2min - Section 22A in 2 minutes
Statutory structure and clause / subsection decode
This map separates the operative limbs of this provision so thresholds, powers, conditions and exceptions are not collapsed into a single summary.
Direct rule
Sections 24, 25, 27, 28 and 39 do not apply to bank notes in digital form issued by RBI.
No notification condition
The statutory exclusion is self-executing in Section 22A; do not add a Government-notification precondition that the section does not contain.
Operational boundary
CBDC design, wallets, pilots and transaction conditions must be sourced separately to RBI operational instruments.
Worked practical example
Facts. A memo says digital banknotes need a Government notification before Section 24 stops applying. That is not the structure of Section 22A: the exclusion of Sections 24, 25, 27, 28 and 39 follows directly from the Act.
Compliance points and common mistakes
- Do not decide the issue from the heading alone. Map the facts to the operative words of Section 22A and to each relevant subsection, clause, proviso or explanation shown above.
- Keep the statutory question separate from the operational overlay. Read Section 22A with Section 22 (RBI's note-issue authority) and the definitions of bank note; operational CBDC design or usage conditions must be sourced to the applicable RBI instrument rather than invented from Section 22A.
- Do not convert an exception, exemption or discretionary RBI/Government power into an automatic entitlement. Record the authority, conditions and effective date.
- Where the provision is historical, omitted or repealed, state that status prominently and do not present it as a current compliance obligation.
Connected provisions and instruments
Questions and answers
What is the purpose of Section 22A?
Non-applicability of certain provisions to digital form of bank notes: Section 22A is a direct statutory carve-out for bank notes in digital form issued by RBI.
Which statutory limb should be checked first?
Direct rule - Sections 24, 25, 27, 28 and 39 do not apply to bank notes in digital form issued by RBI.
What is the next legal boundary?
No notification condition - The statutory exclusion is self-executing in Section 22A; do not add a Government-notification precondition that the section does not contain.
What record should support the conclusion?
Section 22A file evidence: For a digital-bank-note issue, identify whether the point is statutory note status, one of the expressly excluded sections, or an operational CBDC rule. Preserve the RBI circular/direction that supplies any operational requirement.
Primary sources
- Department of Financial Services - consolidated RBI Act (states amendments through Finance Act, 2022)
- India Code - Reserve Bank of India Act, 1934