India's new labour codes: From reform to readiness
Thought leadershipTen months after India's four labour codes came into force, employers are applying them across pay, benefits, contract labour, working hours and social security.
The Reserve Bank of India (RBI) has introduced a landmark reform in credit risk assessment through its Draft Directions 2025, proposing a shift to the Expected Credit Loss (ECL) framework. This forward-looking approach marks one of the most significant changes in Indian banking regulation since the adoption of prudential norms in the 1990s.
Why the ECL framework matters
India’s current provisioning model is retrospective, relying on fixed provisioning rates and asset classification based on overdue days. This often delays risk recognition and treats all borrowers similarly—whether AAA-rated or C-rated—until signs of default appear.
Globally, the IFRS 9 standard introduced forward-looking credit loss models in 2018, which India adopted for NBFCs and corporates under Ind AS 109. However, banks have been awaiting a prudentially aligned version. The RBI’s proposed ECL framework fills this gap, enabling:
- Early risk detection
- Improved capital planning
- Alignment with global standards
This will enhance the resilience, transparency, and credibility of India’s banking system.
Key features of RBI’s proposed ECL framework
The framework applies to scheduled commercial banks, including foreign banks, and introduces a risk-sensitive approach to provisioning. It replaces the rule-based model with estimates based on:
- Probability of default (PD)
- Loss given default (LGD)
- Exposure at default (EAD)
These estimates must incorporate historical data, current credit conditions, and macroeconomic forecasts. The definition of “default” remains consistent with existing NPA norms to ensure continuity.
To support accurate implementation, banks must adopt:
- Robust model validation and back-testing
- Board-level oversight
- A five-year phased transition for regulatory capital impact
Scope and applicability
The ECL framework covers:
Loans
Debt securities (not measured at FVTPL)
Trade and lease receivables
Loan commitments and undrawn limits
Off-balance-sheet exposures
(e.g., guarantees, letters of credit)
Any financial asset with a contractual right to receive cash
Notably, non-funded exposures like bank guarantees and unutilised credit limits will now require ECL provisioning. For such instruments, the date of irrevocable commitment is considered the point of initial recognition for impairment assessment.
Exclusions
The framework currently excludes:
- Regional Rural Banks (RRBs)
- Small Finance Banks (SFBs)
- Payments Banks
- Co-operative Banks
These exclusions reflect operational challenges such as limited data availability and high exposure to unsecured lending. However, this creates a two-tier system. A time-bound roadmap for convergence and shadow ECL runs could help bridge the gap.
Transition to Effective Interest Rate (EIR)
The RBI also proposes a shift in income recognition from contractual interest rates to the Effective Interest Rate (EIR) method, aligning with IFRS 9/Ind AS 109.
Implications of EIR
- Reflects the true economic yield of financial instruments
- Requires reclassification of fees and system upgrades
- Challenging for legacy portfolios lacking detailed records
To ease implementation, RBI may consider applying EIR prospectively to new loans only.
Governance and oversight
The RBI mandates a strong governance framework for ECL implementation:
- Oversight by the Board of Directors
- A dedicated ECL subcommittee (including CFO and CRO)
Responsibilities include:
- Reviewing strategy and methodology
- Ensuring data integrity and model independence
- Monitoring KPIs and regulatory compliance
This promotes accountability, consistency, and transparency in credit risk management.
Enhanced disclosures for transparency
Banks must provide detailed disclosures in financial statements to help stakeholders understand the impact of credit risk. Key requirements include:
1.
Movement analysis of ECL allowances
2.
Overview of ECL methodology and assumptions
3.
Exposure and concentration details
4.
Criteria for significant credit risk increase
5.
Impairment recognition and write-off policies
6.
Use of macroeconomic inputs and forward-looking data
7.
Reconciliation of opening and closing ECL balances segmented by:
- 12-month ECL
- Lifetime ECL for increased credit risk
- Credit-impaired assets
Prescribed formats (Annexure 4) will guide disclosures on credit quality, loan summaries, and macroeconomic assumptions. Supplementary disclosures are encouraged for clarity.
Proposed ECL framework for Banks in India
October 2025
Our insights
The future of UPI: Why Zero MDR matters for India
Thought leadershipThe introduction of India's Unified Payments Interface (UPI) has changed the face of the country's payment system by providing millions of people with the ability to carry out real-time, interoperable and secure digital transactions.
Why CFOs are prioritising skills and technology over headcount
Chapter 5Finance leaders want to focus on strategy, but day-to-day demands still take up much of their time.