The issuer remains accountable for the arrangement
Under the RBI Commercial Banks credit- and debit-card Directions, co-branding does not transfer the issuing bank’s responsibilities to a merchant, platform or other partner. The current text, updated on 1 October 2026 and checked on 26 October 2026, restricts partner roles and transaction-data access while requiring the issuer to ensure timely delivery of advertised partner benefits. An attractive reward calculation cannot compensate for an arrangement that fails those operational requirements. RBI: Commercial Banks card Directions, 2025, updated 1 October 2026, paragraphs 3 and 54–63.
Check the issuing institution and the card category
This article applies the Reserve Bank of India (Commercial Banks – Credit Cards and Debit Cards: Issuance and Conduct) Directions, 2025, paragraphs 54–63. Their Commercial Banks definition excludes Small Finance Banks, Payment Banks and Local Area Banks. Do not assume this instrument alone determines every requirement for every issuer or prepaid product. The chapter also preserves specific conditions applicable to the relevant card type. Identify the actual regulated issuer before testing a co-branded proposition.
Make the issuer and commercial relationship visible
Paragraphs 55–58 address clear identification of the co-branding arrangement, prominent issuer branding and disclosure of revenue-sharing information to the cardholder and on the issuer’s website. The partner should not market the card as its own product. The bank’s approved policy and due diligence should address the arrangement’s risks, and a financial partner must have the necessary approval from its own regulator. Check the current approved policy rather than recycling an older mandatory-policy description.
Distinguish secure cardholder display from partner access
Paragraph 62 prohibits the partner from accessing information about co-branded-card transactions irrespective of another service it supplies to the issuer. It permits transaction data to be drawn directly from the issuer’s system in encrypted form for secure display on the partner platform for cardholder convenience, provided the information is visible only to the cardholder and neither accessed nor stored by the partner. A backend data warehouse or employee dashboard is different from that limited display route. The RBI’s earlier FAQ, question 15, also explains that acting as a technology provider or business correspondent does not create unrestricted access. The current Directions govern this article’s scope.
Keep partner activity within the permitted role
Paragraphs 61–62 limit the tie-up role to marketing/distribution and access to the offered goods or services. After issue, the partner should not participate in card processes or controls except as an initial grievance contact, subject to the limited display arrangement. Being a convenient complaint entry point does not shift the bank’s responsibility. Review actual user permissions, application flows, logs and support procedures; a compliant contract clause cannot establish that a different live implementation complies.
Reconcile promised benefits to what the cardholder received
Paragraph 60 makes the issuer liable for partner acts and for delay or non-delivery of advertised cashbacks, discounts and other offers. Build an offer-specific working covering eligibility, exclusions, caps, reversals and the promised delivery date. These commercial terms are not RBI-prescribed universal reward rates or deadlines. Avoid multiplying an assumed percentage by all spending where the offer has exclusions or monthly limits. Retain the offer version and settlement evidence, and route exceptions to the issuer’s accountable process.
Applicable primary references
RBI: Commercial Banks card Directions, 2025, updated 1 October 2026, paragraphs 3 and 54–63 RBI earlier card Directions FAQ: question 15 on co-branding partner data access
Six worked illustrations
All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.
Illustrative example 1: A capped cashback promise
A fictional offer pays 2% of eligible spending, capped at ₹500 for the relevant month. Eligible spending is ₹32,000. The uncapped calculation is ₹640, so the promised benefit is ₹500. If ₹450 is credited, the shortfall is ₹50; RBI does not prescribe this 2% rate or cap.
Illustrative example 2: Exclude spending the offer does not cover
Assume total spending ₹50,000 includes ₹12,000 expressly excluded by a valid fictional offer. The eligible base is ₹38,000. At the assumed 1.5% rate, the benefit is ₹570. Applying that rate to all ₹50,000 would overstate the benefit by ₹180.
Illustrative example 3: Apply a stated transaction discount cap
A fictional partner advertises a 10% eligible-purchase discount capped at ₹1,000 per purchase. On an eligible ₹18,000 purchase, 10% is ₹1,800 but the promised discount is ₹1,000. Subject to the stated offer mechanics, the net purchase amount is ₹17,000. Do not describe the ₹1,800 uncapped figure as the delivered saving.
Illustrative example 4: Use the offer’s documented delivery date
Assume a fictional cashback must be credited by 15 November 2026 under its terms. It is credited on 24 November 2026. The elapsed delay is nine calendar days. Record that contractual delay without inventing a nine-day statutory penalty or a universal RBI cashback deadline.
Illustrative example 5: Test partner-side data copies
A controlled test reviews 120 transaction-display events. All 120 are displayed to the relevant cardholder, but 12 transaction payloads are also retained in a partner-accessible analytics store. The observed partner-stored population is 12 of 120, or 10%. The display success does not cure those copies; the percentage is an audit finding, not a permitted tolerance.
Illustrative example 6: Reconcile reversals and incomplete settlement
A fictional 1% offer covers ₹80,000 of initially eligible purchases and validly reverses benefits on ₹10,000 of refunded purchases. Net eligible spending is ₹70,000 and the benefit is ₹700. If ₹600 has been credited, the unsettled promised benefit is ₹100. Keep refund evidence and the offer’s reversal terms with the reconciliation.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Identify the regulated issuer | Institution type and applicable current card Directions. |
| 2 | Classify the product | Credit, debit or other card-specific framework. |
| 3 | Inspect issuer branding | Card face and marketing clearly identify issuer and co-branding. |
| 4 | Review disclosures | Cardholder and website revenue-sharing information under paragraph 58. |
| 5 | Check policy and due diligence | Approved policy, partner risk assessment and regulatory approvals where relevant. |
| 6 | Map partner activities | Marketing, offered services and initial grievance contact versus card controls. |
| 7 | Test the display route | Issuer-origin encrypted data, robust security and cardholder-only visibility. |
| 8 | Inspect partner storage and access | Actual data flows, stores, analytics and staff permissions. |
| 9 | Recalculate promised benefits | Offer version, eligibility, caps, reversals and stated credit dates. |
| 10 | Close issuer-owned exceptions | Shortfalls, delays, data issues and evidence of corrective action. |
Sixteen practitioner FAQs
1. Does co-branding make the partner the card issuer?
No. Identify the regulated institution that actually issues the card.
2. Can the partner market the card as entirely its own product?
Paragraph 55 prohibits marketing the co-branded card as the partner’s own product.
3. Must the issuer’s branding be prominent?
Yes, paragraph 56 addresses prominent issuer branding.
4. Can a card have more than one co-branding partner?
Paragraph 57 permits that arrangement.
5. Is revenue sharing only an internal commercial matter?
Paragraph 58 requires relevant information to be indicated to cardholders and displayed on the issuer’s website.
6. Does technology-provider status permit transaction access?
No. Paragraph 62 applies irrespective of another service provided to the issuer.
7. Is every transaction display on a partner app prohibited?
No. The limited encrypted, secure, issuer-origin cardholder-only display route has specific conditions.
8. Can the partner store that displayed information for analytics?
The permitted display wording says the partner must neither access nor store it.
9. Does a customer-facing screen prove backend compliance?
No. Test backend stores, logs, permissions and data flows as well.
10. May the partner manage post-issue card controls automatically?
Do not infer that authority; paragraph 62 restricts post-issue involvement.
11. Can the partner receive an initial grievance?
That is the stated exception to the post-issue role restriction.
12. Does the bank escape responsibility for a partner’s delayed cashback?
No. Paragraph 60 makes the issuer liable for delay or non-delivery of advertised benefits.
13. Does RBI prescribe the example reward percentages?
No. They are expressly fictional commercial terms.
14. Is there one cashback delivery deadline for every offer?
Do not invent one. Test the actual advertised terms and the timely-delivery obligation.
15. Does this Directions document cover every type of bank?
Its Commercial Banks definition has exclusions; identify the correct applicable instrument for the issuer.
16. What is the most useful evidence package?
The current contract and offer terms, issuer disclosures, actual data-flow tests and benefit-settlement reconciliation.
Conclusion
Co-branding does not give a partner unrestricted card-transaction access. Check issuer visibility, partner roles, secure display and timely delivery of advertised benefits.