For the covered domestic ATM or micro-ATM incident where the account is debited but cash is not dispensed, RBI’s failed-transaction framework requires proactive reversal within T+5 days and ₹100 for each day of delay beyond that limit. T is the calendar date of the transaction. Compensation must be credited without waiting for a claim. See the 20 September 2019 framework, Annex item 1(a) and RBI’s ATM FAQ.
Match the incident before starting the clock
The framework concerns failed authorised-payment-system transactions for reasons not attributable to the customer. It covers domestic transactions as described in the circular. An unauthorised withdrawal, a complaint that the wrong denomination was received, disputed partial cash dispensing or an international ATM transaction should not be forced into this example without checking the relevant facts and route. A successful withdrawal followed by theft is not the same as debit-with-no-cash failure.
The circular was effective from 15 October 2019. RBI’s ATM FAQ, marked updated on 4 July 2025, confirms the maximum of five calendar days and the card-issuing bank’s compensation obligation. Calendar days include intervening weekends and holidays; a branch’s working-day calendar does not create a longer T+5 period. A complaint date does not restart the transaction-date clock.
Maintain two balances: principal and compensation
Keep the original account debit, reversal credit and compensation credit as separate entries. The principal refund restores the wrongly debited amount; it is not the compensation itself. For a completed delayed reversal, the simple working is the number of calendar days after the T+5 date up to actual reversal, multiplied by ₹100. A reversal within the outer limit generates no delay compensation under this specified measure, although quicker resolution remains the regulatory objective.
The circular defines R as the date reversal is concluded and funds are received by the issuer/originator, and requires reversal at that end on the same day funds arrive from the other end. Obtain the actual account-credit evidence and investigate a mismatch between interbank status and customer credit rather than treating a generic resolved ticket as proof that money arrived. No example awards extra interest on the compensation or assumes an unlimited additional head of damages.
Evidence and escalation
Record transaction date/time, amount, ATM identification, reference number, issuing bank and available receipt or message. Report promptly to the issuing bank, retain acknowledgement and ask for reversal and separately calculated compensation. Do not disclose the PIN or OTP in a complaint. Reconcile any later credits individually where several failures occurred; one combined credit can hide an unresolved transaction.
The circular permits escalation through the Reserve Bank Integrated Ombudsman Scheme for failures of redress, subject to that scheme’s conditions. Follow the applicable complaint process rather than assuming the circular removes all eligibility and prior-complaint requirements. The examples assume genuine covered incidents, full principal reversal on the stated date and no attributable customer fault. They use completed hypothetical cases to demonstrate the dates, not unresolved live bank claims.
Six worked illustrations
All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.
Illustrative example 1: Reversal on the outer-limit date
A covered ₹5,000 failure occurs on 1 November 2026. T+5 is 6 November 2026. Full reversal on 6 November is within the stated outer limit, so this delay-compensation working is ₹0. The ₹5,000 reversal remains a principal restoration.
Illustrative example 2: One day late
A ₹2,000 failure occurs on 1 November 2026 and is fully reversed on 7 November. T+5 is 6 November; delay beyond it is one calendar day. Compensation is ₹100 and principal plus that compensation totals ₹2,100, recorded as separate credits.
Illustrative example 3: Crossing a month end
A ₹10,000 failure occurs on 31 January 2027. T+5 is 5 February 2027. Reversal on 8 February is three days late and compensation is ₹300. The customer should distinguish the ₹10,000 principal credit from ₹300 compensation.
Illustrative example 4: Leap-year date working
A covered failure on 28 February 2028 has a T+5 date of 4 March 2028 because 2028 includes 29 February. Full reversal on 6 March is two days late, producing ₹200. This is a calendar illustration, not a bank-holiday adjustment.
Illustrative example 5: Two failures require two clocks
Covered failures of ₹3,000 on 1 November 2026 and ₹4,000 on 2 November are both fully reversed on 8 November. Their T+5 dates are 6 and 7 November. Delays are two days and one day, giving compensation of ₹200 and ₹100, or ₹300 total, alongside ₹7,000 total principal restoration.
Illustrative example 6: A later complaint does not restart T
A ₹6,000 failure occurs on 1 November 2026. The customer complains on 8 November and receives full reversal on 9 November. The T+5 date remains 6 November, so delay is three days and compensation ₹300. Counting only from the complaint would incorrectly erase part of the regulatory clock.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Confirm the incident | Domestic account debit with no cash dispensed and covered failure facts. |
| 2 | Identify the issuing bank and ATM | Transaction reference, ATM identifier and account evidence. |
| 3 | Fix T | Actual transaction calendar date and time. |
| 4 | Calculate T+5 | Calendar-date addition including weekends and holidays. |
| 5 | Record reversal evidence | Full principal credit and any mismatch with system closure status. |
| 6 | Calculate delay days | Actual reversal date less the T+5 date, floored at zero. |
| 7 | Compute compensation | ₹100 multiplied by the supported delay days. |
| 8 | Separate ledger credits | Principal restoration distinguished from compensation. |
| 9 | Track the bank response | Acknowledgement, reference, explanation and outstanding credits. |
| 10 | Escalate appropriately | Applicable grievance and Ombudsman conditions checked with the complete evidence file. |
Sixteen practitioner FAQs
1. What incident does this guide cover?
The specified domestic ATM/micro-ATM account-debited-but-no-cash-dispensed failure.
2. What is T?
The transaction’s calendar date, not the later complaint date.
3. Are the five days working days?
No. The framework and FAQ use calendar days.
4. Does a weekend extend the ordinary limit?
Not by replacing calendar days with branch working days.
5. When does delay compensation start?
For delay beyond the T+5 outer limit in the covered incident.
6. How much is the daily amount?
₹100 for each supported day of delay under this measure.
7. Is the principal refund itself compensation?
No. Record restoration of the debit separately from compensation.
8. Must the customer first submit a compensation claim?
The circular requires compensation suo motu, without waiting for a complaint or claim.
9. Should a complaint still be made promptly?
Yes. Preserve the evidence and request both the reversal and the separate compensation reconciliation.
10. Does the amount withdrawn set the daily rate?
The specified rate is ₹100 per delay day; it is not a percentage of the withdrawal.
11. Can multiple failures share one date working?
Calculate each transaction separately before reconciling combined credits.
12. Is a resolved service ticket proof of credit?
No. Verify the actual account entry and investigate any interbank/customer-credit mismatch.
13. Does this cover an unauthorised cash withdrawal?
That requires a separate unauthorised-transaction analysis, not automatic use of this failed-withdrawal model.
14. Does it decide partial cash-dispensing disputes?
No. Establish the incident and applicable redress treatment from the actual facts.
15. What if the ATM is a white-label ATM?
RBI’s FAQ describes customer use of WLAs alongside bank ATMs; retain the issuing-bank and terminal evidence for the covered complaint.
16. Can a complaint go straight to Ombudsman without conditions?
Check the applicable scheme’s process and eligibility; the failed-transaction circular does not remove those requirements.
Conclusion
Reconcile a domestic ATM debit with no cash dispensed using RBI’s T+5 reversal limit and ₹100-per-day delay compensation, keeping the principal refund and compensation separate.