The linked account is the first issuance check
RBI’s Commercial Banks – Credit Cards and Debit Cards: Issuance and Conduct Directions, 2025 permit debit cards only for customers with savings-bank/current accounts, prohibit issuance to cash-credit/loan accounts and preserve the stated PMJDY and Kisan Credit Card linkage exceptions. Banks must not force debit cards on customers or condition another facility on taking one. This guide uses paragraphs 45–50, updated as on 1 October 2026 and checked on 26 October 2026. It addresses the issuance and review controls, not a customer’s entitlement to any particular transaction limit or loan. RBI Commercial Banks card Directions, 2025, updated 1 October 2026: paragraphs 3, 45–50.
Keep the bank and product perimeter precise
These Directions define Commercial Banks to exclude Small Finance Banks, Payment Banks and Local Area Banks. Do not automatically extend this article to those institutions, co-operative banks, NBFCs or prepaid payment instruments. A product’s marketing name is not sufficient to classify it: inspect the legal issuer, linked account and whether it is actually a debit or credit card. The credit-card chapter’s business-credit-card permissions do not remove the debit-card chapter’s account restrictions.
Read the account restriction and its exception together
Paragraph 46 identifies savings-bank/current-account customers. Paragraph 47 prohibits debit-card issuance to cash-credit/loan accounts, while not precluding linkage of the overdraft provided with PMJDY accounts or Kisan Credit Card accounts with a debit card. This is a stated exception, not general permission to attach a debit card to any business overdraft. An ordinary savings/current-account card and a separate borrowing facility should be mapped independently; a common customer identity does not merge the accounts or their permissions.
Voluntary issuance must survive the sales process
Paragraph 48 prohibits both forced uptake and tying issuance to another banking facility. Record the customer’s decision separately from the loan or account application. A tick-box selected by default, a package name or a sales target is weak evidence of a voluntary choice if refusal blocks an unrelated facility. Conversely, a customer’s decision not to take a debit card does not by itself settle the eligibility or commercial terms of the other requested facility. Distinguish the anti-tying rule from a promise that a loan must be sanctioned.
Approval and review are bank controls
Paragraph 45 requires a comprehensive issuance policy approved by the Board or a committee delegated that power; separate RBI prior approval for issuing debit cards is not required. Paragraph 49 requires a half-yearly operational review including usage analysis, long-unused cards and associated risks. It does not prescribe the credit-card chapter’s more-than-one-year/30-day automatic closure sequence for debit cards. Use the bank’s applicable policy and other relevant directions for blocking, deactivation and customer communication.
Preserve the policy-to-operation trail
Paragraph 50 requires comprehensive policies/procedures covering issuance, co-branding where applicable, discretionary blocking/deactivation/suspension, the period for completing formalities after blocking a lost card, and grievance/compensation arrangements. The delegated approval route does not remove the need for the actual procedures. A sample audit should link each card to its account, issuance decision, exception evidence and operational status. Record gaps separately from confirmed regulatory breaches and do not infer a mandatory compensation sum from paragraph 50 alone.
Useful boundaries for compliance teams
A facility’s sanctioned amount is not automatically a debit-card spending limit. Nor does unused credit or an account balance prove authority to make a transaction. Customer-set limits, bank limits, security controls, available balance and other applicable rules must all be considered. The arithmetic below is for control inventories and assumed limits; it supplies no RBI-mandated card limit, annual fee, closure deadline or compensation tariff.
Applicable primary references
RBI Commercial Banks card Directions, 2025, updated 1 October 2026: paragraphs 3, 45–50
Six worked illustrations
All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.
Illustrative example 1: Separate ordinary accounts from a loan account
A sample has 120 debit-card records: 80 savings-linked, 25 current-linked and 15 linked directly to ordinary loan accounts with no PMJDY/KCC exception. The first two categories total 105; the 15 loan-linked records form the account-linkage exception population for investigation. The 105 still require their other issuance controls.
Illustrative example 2: Verify an exception rather than accepting its label
Among 24 records flagged as exceptional linkages, evidence supports 9 PMJDY-overdraft linkages and 7 KCC-account linkages. Supported exceptions total 16, leaving 8 unresolved. A spreadsheet label does not convert those eight into permitted linkages; obtain the actual account and facility evidence.
Illustrative example 3: Do not substitute the sanctioned loan limit
Assume a valid savings-linked debit card has a customer limit ₹20,000 and bank limit ₹50,000; the customer separately holds a ₹3,00,000 loan. A proposed ₹35,000 card transaction exceeds the assumed customer limit by ₹15,000. The loan sanction does not raise the card limit or authorise debit-card issuance to that loan account; actual available funds and controls also matter.
Illustrative example 4: Reconcile half-year review coverage
For a bank-defined January–June review, the inventory is 10,000 cards. The usage dataset includes 9,640, leaving 360 omitted records. Reconcile the 360 before presenting the analysis as complete. The bank-defined review period is an illustration of its half-yearly control, not an RBI-prescribed universal review date.
Illustrative example 5: Separate unused cards from all cards reviewed
A complete population contains 2,400 cards, of which 420 meet the bank’s documented long-unused definition. The flagged proportion is 420 ÷ 2,400 = 17.5%. Analyse risk and policy action; the percentage does not itself create an automatic debit-card closure mandate or import the credit-card inactivity timetable.
Illustrative example 6: Investigate tied-sale evidence
In 60 sampled facility applications, 44 contain a separate recorded voluntary debit-card choice, 10 show no card requested and 6 contain evidence that another facility was made conditional on taking a debit card. The six flagged cases are 10% of the sample. Investigate the evidence and correct the process; do not describe the remaining 54 as fully compliant without reviewing their other controls.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Confirm the issuer’s regulated category | Commercial Bank definition and legal issuer identity. |
| 2 | Classify the actual card product | Debit-card contract rather than marketing terminology. |
| 3 | Map the linked account | Savings/current, cash-credit, loan or stated exception. |
| 4 | Validate any PMJDY/KCC exception | Actual account records and relevant overdraft/facility terms. |
| 5 | Inspect voluntary customer choice | Application, consent trail and absence of forced uptake. |
| 6 | Test facility bundling | Refusal scenarios, sales scripts and conditional-sanction evidence. |
| 7 | Verify policy approval authority | Board approval or properly delegated committee authority. |
| 8 | Reconcile the half-yearly review population | Complete card inventory, usage and long-unused-risk analysis. |
| 9 | Check operational procedures | Blocking, lost-card formalities, grievances and compensation framework. |
| 10 | Close exceptions with evidence | Account corrections, customer communication and documented risk decisions. |
Sixteen practitioner FAQs
1. Which banks does this article cover?
The Commercial Banks defined in the cited Directions; their definition excludes Small Finance Banks, Payment Banks and Local Area Banks.
2. Can a product name settle whether a card is debit or credit?
No. Verify the issuer, contract, linked account and operative product terms.
3. Which ordinary account types support debit-card issuance?
Paragraph 46 identifies savings-bank/current-account customers.
4. Can a debit card be issued directly to an ordinary loan account?
Paragraph 47 prohibits that, subject to its specifically stated exception.
5. Does the prohibition also mention cash credit?
Yes. Cash-credit accounts are expressly covered.
6. What is the PMJDY exception?
Paragraph 47 does not preclude linking the overdraft provided along with PMJDY accounts with a debit card.
7. What about Kisan Credit Card accounts?
The same paragraph expressly preserves debit-card linkage for KCC accounts.
8. Is every business overdraft within that exception?
No. Do not expand the specific wording to all overdrafts.
9. May a bank force a customer to take a debit card?
No. Paragraph 48 prohibits forced uptake.
10. Can another facility be made conditional on taking the card?
Paragraph 48 also prohibits that linkage.
11. Does declining a card guarantee loan approval?
No. The anti-tying rule does not remove independent loan eligibility and underwriting requirements.
12. Does debit-card issuance need individual RBI prior approval?
Paragraph 45 says prior RBI approval is not necessary for banks desirous of issuing debit cards.
13. Who approves the issuance policy?
The Board or a committee to which the Board has delegated the powers, under the current text.
14. How often must operations be reviewed?
Half-yearly, including card usage and long-unused cards’ inherent risks.
15. Must an unused debit card follow the credit-card closure clock?
Do not import that separate chapter’s clock. Apply the debit-card policy and relevant applicable directions.
16. Does paragraph 50 itself specify a universal compensation amount?
No. It requires the stated policy/procedure framework; a particular compensation claim needs its applicable legal and factual basis.
Conclusion
Check debit-card account linkage separately from credit-card rules: eligible accounts, PMJDY/KCC exceptions, voluntary issuance and half-yearly review controls.