What changed
The 2026 amendment inserts six new definitions into the 2025 Responsible Business Conduct directions. It clarifies what constitutes compulsory bundling, dark patterns, and the roles of DSAs/DMA and their sub‑agents. It also defines explicit consent and expands the definition of mis‑selling to cover unsuitable products, misleading information, lack of consent, and forced bundling.
What it means for you
Banks must audit their product‑bundling practices to avoid compulsory bundling. Marketing channels, including third‑party agents, must obtain explicit, documented consent before selling. Any deceptive UI or misleading information now falls under dark patterns and mis‑selling, exposing LABs to regulatory scrutiny.
What you must do
- Review and update marketing protocols to ensure no compulsory bundling
- Implement robust consent capture mechanisms
- Train DSAs/DMA and sub‑agents on new definitions and compliance
- Audit digital interfaces for dark patterns
- Update internal compliance manuals and reporting templates
Who it affects
Local Area Banks, DSAs/DMA, Sub‑agents, Customers
When do the new definitions apply?
Effective from January 1, 2027
What is compulsory bundling?
A practice where a customer can avail one product only if another product is also purchased.
How to ensure compliance with explicit consent?
Record a clear affirmative action or documented statement before any sale.