RBI CIC Regulations

“Brutus is an honorable man.” – Mark Antony, Julius Ceaser Act III Scene II, William Shakespeare

In January 2015, the Reserve Bank of India (RBI) made it mandatory for all Credit Institutions (CIs) of India to become members of all Credit Information Companies (CICs).

A Credit Institution is any entity in the business of lending money to customers. This ranges from large banks like HDFC Bank to village-level formal peer-lending systems. This article focuses on Non-Banking Financial Companies (NBFCs), particularly, small NBFCs.

An NBFC is any company that is engaged in the business of lending money, acquisition of securities, hire-purchase insurance business, or chit-fund business which, as the name suggests, does not have a banking license. Hence, an NBFC cannot borrow from the RBI at low rates of interest. Most NBFCs are not allowed to accept public deposits either. This leads to scaling issues and hence NBFCs do not grow as big as banks. Of course, being an NBFC is the route of becoming a bank for most companies. This also means a less-strict regulatory regime on NBFCs compared to banks. As of April 2026, there were 9075 NBFCs in India. Due to their higher cost structure, NBFCs operate in a riskier segment of the market – small businessmen, household women, gold loans, small corporates, farmers etc.

A CIC is a company registered with the RBI that is in the business of collecting and disseminating credit information. There are four CICs in India. The most famous CIC is TransUnion CIBIL having a 70% market share in the Indian market. Others are Experian India (16%), CRIF High Mark (10%), and Equifax India (4%). Together with the RBI, the four CICs create the credit information infrastructure for India.

It is logical that lenders regulated under the RBI should report their lending activities on a periodic basis, so that other lenders interacting with a potential borrowers have knowledge of the credit behaviour of the customer. Put simply, whenever a customer walks into a bank for availing a loan, the first thing the bank does is check the CIBIL score of the customer. This is the first step in any lending process. And to increase transparency among lenders, the RBI in January 2015 mandated that all lenders make mandatory reporting to all four CICs in the country.

Which is where the problem begins.

1.      Why not a central repository?

This is the simplest, most obvious, and overlooked solution to the problem. Instead of 9k NBFCs reporting their credit information to all 4 CICs, they could simply report it to one. And the 4 CICs could work with the RBI to create a central repository of such credit data. This would release some unnecessary compliance burden and the corporate could focus on being a corporate.

This has been suggested to the RBI several times who have taken the idea in consideration and rejected it for reasons unknown.

2.      Unequal relationship with NBFCs

By mandating that every NBFC in the country be registered with every CIC, this gave CICs a semi-regulatory power. Now any CIC could threaten any NBFC with mandatory registration. A registration is a contract where terms must be met by both parties. But the terms of registration with a CIC are set by the CIC with NBFCs having no say. This creates an unequal relationship between two private entities mandated by state decree.

For example, the NBFC must set one nodal officer for all communications with the CIC. However, the CIC is allowed to create bureaucratic red tapes for the NBFC to struggle through various functional teams of the CIC. Any lapse that occurs out of this system can be easily blamed on the NBFC while the CIC was just following procedures.

3.      Private for-profit nature of CICs

Contrary to popular belief, CICs are not government bodies. In fact, they aren’t even Indian. 92% of CIBIL is owned by TransUnion, an American multinational group with headquarters in Chicago. Experian India is owned by Experian plc, Ireland; CRIF High Mark is owned by CRIF S.p.A., Italy; and Equifax India is owned by Equifax Inc, USA.

As per RBI mandates, every credit transaction in the country needs to be reported to all four of these CICs. So the next time you apply to a bank for a loan and they check your credit history on CIBIL, do not be surprised if you start getting calls from all kinds of spam callers offering you loans. Your private data is being sold on a real-time basis, not by Indian banks, but by entities far outside the control of the Indian regulatory regime. As per the RBI, this is a necessary cost to promote credit transparency in the country.

4.      Regulatory Powers to CICs

Under the CIC Regulations, 2006, CICs can report members who do not submit the credit information on time. With the January 2015 circular, CICs can now mandate every NBFC in the country to mandatorily report their credit information. This effectively makes NBFCs a hostage to the CICs. Given that CICs are private entities, their concern is not the well-being of the NBFCs, but the pursuit of profits. CICs have cumbersome systems which cannot be navigated by small companies who lack a dedicated reporting department. This allows CICs to sell software and compliance services through third-party agencies to ease the compliance burden on the NBFCs. The classic case of making money by solving a problem that didn’t exist in the first place. All under the garb of RBI regulations. Contrary to Uncle Ben’s wisdom, RBI’s decree of compulsory registration has given CICs inordinate power, but very little responsibility.

5.      Double profiteering

It is the duty of a CIC to collect and disseminate information. It collects information from its members, and it disseminates information to anyone who is willing to pay for such information. The RBI has made it mandatory for banks to check for CIC scores of potential borrowers before proceeding with any credit transaction. The RBI has also made it mandatory for all credit institutions to submit such credit information to the CICs. CICs charge money at both ends of the information stream, for receiving as well as disseminating information. If it is the duty of the CIC to collect information, then why are NBFCs paying money to the CICs to submit information?

This goes back to the unequal relationship where NBFCs must adhere to the terms specified by the CICs to be registered where the CIC mandates NBFCs to pay up to be registered.

6.      Use of Spam Bots

If you’ve ever had the (mis?)fortune of interacting with CIBIL, you would know that they do not use normal Indian numbers. The call would typically come from a foreign number and would be marked spam by whatever CallerID service you use.

If you do pick up the call, you will be told that CIBIL is recording the call. But if you were to ask for that recording in case of a dispute, then CIBIL would somehow lose that recording.

If you do manage to make it through a call, you would realize its always to sell something. Either it is your own credit score, or a credit score management software, or some third-party who got your number from CIBIL and want to sell you services that will improve your credit score. Ultimately, the data and attention of Indians is for grabs to the highest bidder.

---

To conclude, the RBI is overlooking a very pertinent problem having an obvious solution. One can only assume incompetence or corruption to allow such issues to persist. The RBI has already mandated data preservation laws for credit card transactions and central repository laws for large borrowers. The same can be implemented for CICs. It is also strange that such a critical infrastructure which forms a cornerstone of modern Indian banking is left to the regulation of four foreign entities who have been given quasi-regulatory powers by the RBI.

Age of Abundance

“Jungle mein mor nacha, kisne dekha?’ (A peacock danced in the jungle, who saw it?)

The question of the dancing peacock has quietly lived in every Hindi-speaking household. It sounds dismissive. But beneath it sits a discomforting thought - if no one saw it, did it even happen?

The same thought is posed in the English counterpart – “If a tree falls in a forest and no one is around to hear it, does it make a sound?”

I ran into this question recently at work. I said that I’m writing, but my blog doesn’t have much reach. In the age of Gen-AI and an explosion of online content, mine was neither famous nor relatable to most people. In fact, I still used a Blogspot domain which has grown redundant in view of the newer platforms like Medium and SubStack. So that question hit me, was I the peacock in the forest that no one was watching?

Why does a peacock dance? Does it dance to show the visiting audience its beautiful feathers? Is it even aware of its own beauty? Or does it dance simply because it is a peacock and that’s what peacocks do. Other birds might dance as well. Other birds might try to paint themselves as peacocks and copy its moves. And might fly on high masts to make themselves more visible to the public eye. But no matter how hard it tries, a crow does not become a peacock. Perhaps because a peacock isn’t trying to be a peacock – it simply is a peacock.

But what happens when the peacock starts measuring its worth by the number of eyeballs it reaches? What happens when the peacock laments that it can’t fly as high as the eagle or swim like the duck. Would it try to fly higher, become more visible? That seems to be a futile question. A peacock doesn’t measure its worth by the likes, comments, and subscriptions of strangers it doesn’t know. The peacock dances for itself. Maybe, it dances for the Creator that has endowed it with feathers. But no more. The world tries to judge the peacock by its views and likes. The peacock simply continues to dance, away from such debates.

In the age of abundance, knowledge is not a scarce resource anymore; it is abundant, almost aggressively so. Neither is meaning or synthesis or any of the traditional indicators of intelligence. With LLMs, one can understand any topic at any level desirable. For example, just the other day I asked ChatGPT to explain thermodynamic entropy using Diogenes’ philosophy; and ChatGPT complied. Knowledge and understanding is available on demand – high in supply. Everyone can learn anything. Everyone can say something. Everyone can publish. Everyone can dance.

The need for public validation runs high and attention has become the commodity that is short in supply. What happens when an explosion of information vies for attention? Attention spans grow shorter. What earlier used to be dopamine rewards have now converted into constant unending streams of dopamine, flushing the mind into overload. That is why you feel exhaustion after scrolling through reels. Not because the information quality is bad – it is in fact the richest humanity has ever had to offer. The human mind has lost the ability to absorb information because it is unable to appreciate anything in depth.

The universe put a lot of effort into creating the potato. First of all, it had to undergo the Big Bang. Then it had to create the Earth. Conditions had to be right for life to emerge underwater. That life had to find a way to breathe air on land. Still clinging to roots, life evolved, adapted, struggled, and survived through possibilities and probabilities – finally to give rise to the potato!

The potato chip is different. First of all, frying the potato alters its chemical composition. It makes for a tastier snack, but does not contain the nutrients built by the efforts of the universe. That is what consumption of information through LLMs and reels is like. It is not food – it is a snack. Getting used to such quick snacks takes away the joy of learning the real thing. The brain is a muscle and like any muscle, it can’t be blown up into strength. It needs to be taught to struggle. To sit with an idea and to think. The age of AI is robbing human brains of the ability to think. Because we do not practice thinking any more. If an AI can do it, why use our own brains?

I remember visiting the Sunderbans. Most people take a river safari in hopes of seeing the Royal Bengal Tiger. I have undertaken many such safaris in my life. There is always that lofty goal of spotting a rare wild beast. Sometimes you’re able to spot it, most times you come back having seen only the marks of it. As I had come back after that trip after seeing the large paw-prints of the tiger on the coasts of islands. I missed seeing the elusive tiger. But the tiger, I suspect, did not feel the same. People came from around the world to watch the Royal Bengal Tiger of the Sunderbans. If only the tiger knew… perhaps he would have been a better host. But I guess that’s the fun of it. You could always see a tiger in your local zoo. But what you want to see is the good fortune of spotting a real tiger in its natural habitat. You wouldn’t want to see a person dressed up in a tiger’s costume running wild in the jungle for your show.

In the age of abundance, we have confused visibility with value. We measure what can be measured – views, likes, reach, engagement. But there are things that resist measurement – thought, stillness, depth, meaning. It is now rare to find the ability to sit with an idea and not rush to resolve it - the ability to not act. The ability to feel something without needing to articulate it. These are things that do not go viral. But they remain, quietly, at the core of what it means to be human.

Our parents grew up in the age of scarcity, where resources were things to be preserved for a rainy day. We grew up in the age of information, where data was gold and knowledge was the real currency. This is the age of abundance, where knowledge is not currency anymore. There is an explosion of content, and we do not know what to do with it. Connection perhaps? Psychologists are repeatedly warning that while we remain infinitely more connected to the world through the internet, humans are lonelier than ever. We don’t relate to others, we don’t relate to ourselves, and we don’t relate to God. The potato has finally abandoned the ground and is now struggling for roots.

So what is the peacock supposed to do – it dances. Because that’s what peacocks do. Perhaps the question was never “who saw it?”, but “would it still dance if no one did?”

PMLA – Delhi Liquor Policy Case 3

The article follows the events described in the author’s previous works being (1) Enforcement Directorate vs. Arvind Kejriwal and (2) PMLA - Delhi Liquor Policy Case. The current article stems from subsequent developments and may be read as an independent piece.

 

BACKGROUND

On 30-Mar-2026, the ED moved to the Delhi High Court challenging the 22-Jan-2026 order of the Rouse Avenue District Court (Trial Court).

As per the original order, the ED had made the allegation that Arvind Kejriwal had deliberately skipped the summons sent by the ED in respect of the investigation in the Delhi Liquor Policy Case. The case had lasted for 22 months 16 days before the trial court finally acquitting Arvind Kejriwal vide a 51-page order. It may be noted that this case was not the trial of the actual money laundering offence, but only restricted to the point of skipping the summons of the ED.

During these 22 months 16 days, Arvind Kejriwal had been arrested, interrogated, arrested again, bailed, interrogated again, bailed again, and discharged in the Delhi Liquor Policy Scam Case.

Now the ED, in its wisdom, has challenged the acquittal of Kejriwal with respect to a summons he did not attend, in a case where the custodial interrogation is over, investigation is already complete, the accused has served jail-time, and has been discharged, with scathing remarks on the conduct of the ED. The remarks of the Trial Court have since been stayed by the Delhi High Court. The ED still believes that it was wrong of the Trial Court to acquit Arvind Kejriwal for not attending the summons.

 

RATIONALE

The purpose of a summons is to question a witness or an accused. The ED has already availed the opportunity of interrogating Kejriwal in custody after arresting him in March 2024. One of the grounds of arrest was also the skipping of the said summons. However, the ED still wants its pound of flesh against Kejriwal for skipping the summons.

But that is not the entire concern here. The non-attendance of a summons is an offence under section 174 of the erstwhile IPC [section 208 of the BNS]. The punishment for such non-attendance is a maximum of one month of imprisonment, or fine of Rs. 500, or both. By any reasonable stretch of imagination, Arvind Kejriwal has already served such punishment. However, the sheer expense of the appearance of senior counsels before the High Court now shall be borne by the taxpayers of India. For a case which shall serve no purpose even if the ED were to somehow win in its obstinate grudge against Arvind Kejriwal.

The natural question arises, why are the taxpayers of the country paying for the punishment for non-attendance in a summons of a person who has already been arrested, remanded, interrogated, and discharged from the case?

The only reasonable explanation in this unreasonable charade is that there were certain legal lacunae in the order of the Trial Court which may be used by future litigants, and hence need to be dispelled before a higher forum. But this argument does not stand on its own legs. Trial Courts are not constitutional courts and their judgements are not quotable. Any court can disagree with the rationale taken by a trial court.

We fail to find any reasonable logic behind the challenge of the acquittal in summons, while the punishment is already infructuous. But as it often happens, when reasonable logics leave the floor, we can think of unreasonable probabilities that might be the reason. Perhaps the ED is only looking to make a media show of Arvind Kejriwal; perhaps the senior counsel simply desires a new car; or perhaps the ED already knows that the discharge of Arvind Kejriwal shall soon be overturned by the High Court. Arvind Kejriwal has already moved to the Supreme Court for a change in the bench at the Delhi High Court, citing reasons of biasness.

The author is not a fan of Arvind Kejriwal. The author is a fan of Jack Daniels whiskey which was not available in Delhi due to the Delhi Liquor Policy under Arvind Kejriwal. So we bear no sympathy towards the then Chief Minister. But after having gone through what Kejriwal has endured, if he thinks that the ED is banking on the bias of the judges in the High Court, we can hardly blame the man.

PMLA - Delhi Liquor Policy Case

The timeline of the Delhi Liquor Policy Scam Case looks like a game of snakes and ladders. For the purposes of this article, we have refrained from going into the merits of the case and the 598-page judgement of the Delhi trial court in the matter. We simply take a look at the timeline which offers some interesting revelations.

• During August-November 2022, the CBI and the ED registered the corruption and money-laundering cases almost simultaneously. The ED then quickly files a chargesheet where Arvind Kejriwal is not named as an accused.
  
  
• In March 2024, the ED arrested Arvind Kejriwal. For the first time in independent India, a sitting Chief Minister of a state was arrested. The Lok Sabha elections were scheduled after two months.
  
  
• By May 2024, the ED had already filed multiple chargesheets in the case. Only in the 7th chargesheet it named Arvind Kejriwal as an accused, after his arrest. This happened just before the elections 2024 Lok Sabha elections.
  
  
• In June 2024, Kejriwal was granted bail by the Delhi trial court. The next day, the bail was stayed by the Delhi High Court upon oral mentioning by the ED. Subsequently, the bail was cancelled by the High Court.
  
  
• After rejection from the High Court, Kejriwal appealed for bail in the Supreme Court. Meanwhile, the CBI emerged. Kejriwal was arrested by the CBI while already in custody in the ED case. Kejriwal secured bail in the ED case but had to continue incarceration because of being arrested by the CBI as well now.
  
  
• In July 2024, The Delhi High Court reserved its order in the bail matter in the CBI case. The same day, the CBI filed its 5th and final chargesheet in the case where Kejriwal was named as an accused for the first time. Then the High Court's order came where Kejriwal's bail was rejected.
  
  
• Finally, Kejriwal secured bail in September 2024 from the Supreme Court and discharge in the entire case in February 2026.
  
  
• This is the second time in three months when a high-profile political ED case has fallen flat because the predicate offence has been invalidated - the previous one being National Herald in December 2025.
  
  
• The government had already challenged the closure of a ED case upon closure of the predicate offence in the National Herald case. This goes against the principles established in various Supreme Court judgements including Vijay Madanlal Choudhury. But the matter remains sub-judice for now.
  
  
• Meanwhile, the government had proposed the 130th Constitutional Amendment Bill in August 2025. It may be time to review that.

Winter has Come

I record these words in the manner expected of a sworn maester of the Citadel, though I fear the quill trembles more from futility than cold. A maester is meant to chronicle wars, lineages, treaties, and the slow workings of governance. For most of my life, I believed such things to be the true machinery of the world, the gears upon which the fortunes of kings and smallfolk alike turned. Yet for years… mayhaps for decades… my memory adheres to dates now only loosely, like old wax to a candle stub. For a long time I warnings of something far simpler and far graver – the Others.

I spoke of them not as the singers do, cladding truth in pretty liesso that a frightened child may sleep; nor as the old maids do, twisting fear into fables to keep children from wandering too far. No, I relied on dusty accounts preserved in rotten parchment and faded ink, the sort of scholarship that kings assume carries no blood. These were not stories. They were records, measurements, testimonies, and observations. Dry things. Tedious things. The sort of things only maesters pretend to find stirring. Yet I believed, with a young man’s stubbornness, that if truth were laid bare plainly enough, even the thickest lord might at last take heed.

I spoke their warnings plainly. I wrote treatises. Tedious, meticulous, footnoted treatises. I implored lordlings and septons, even the Citadel itself. I spoke to any steward or captain or hedge knight fool enough to lend an ear – but few cared to listen. Few cared. Fewer still believed. Those who did were dismissed as fools – men unhinged from reason, or worse, men seeking attention.

A wandering wildling would sometimes stagger south of the Wall bearing warnings – breathless fragments about the dead stirring, the woods whispering, the cold walking. These men had little in the world – no property, no noble sigil, not even a name worth recording. Their words were worth even less. They were waved away with the same casual motion one uses to scatter crows from grain.

The North was supposed to remember. A proud boast, repeated around hearths, embroidered on banners, recited with the solemnity of prayer, etched into the very identity of their houses. But remembering is not the same as understanding. They remembered the words, not the meaning. They repeated winter is coming as one might repeat the humdrum greeting of a passing acquaintance, never pausing to ask what winter meant, what it required, what harbingers announced its arrival, or what winter demanded of them.

Winter does not always announce itself with roaring winds and white horizons. It begins subtly. A frost lingering longer than it should. A sickness that spreads in odd patterns. Crops that turn to grey mush before harvest. A dull haze clinging to the air, dimming the sun to a copper smear. A strange stillness in the city.

All things I dutifully noted, dated, compared with records centuries old. It was my duty to be dull, and I was dutiful in it. I presented my findings before maesters far more learned than I – men who had forgotten more than I would learn in a lifetime – they nodded politely while their eyes drifted to more fashionable concerns – trade fleets, naval skirmishes, the lineage of some minor house’s third son.

So winter bided its time. Then it leapt.

It happened faster than any chronicle could capture. Villages emptied overnight. At first one. Then three more. Then dozens. Ravens stopped returning. The forests to the far north went silent. When the truth could no longer be denied, the great lords sent out their men, but swords and shields forged in the south do little against cold that devours not only flesh but will. Steel cannot wound cold. The Wall fell. the winds that followed were not winds at all, but something older wearing wind as a mask.

Still I wrote. I recorded. It is the maester’s duty. I noted the creeping chill in my bones, the dimming of the sun, the way ink froze at the tip of the quill before I could shape a full sentence. I wrote even when my breath smoked and vanished faster than I could draw the next. I can hear them outside – patient, tireless, without breath or warmth or haste. They have no need for haste.

I had believed, foolishly, that scholarship might serve as shield. I thought knowledge, once shared, would rouse men to action. But the scrolls gathered dust while the world burned white. Men preferred their comforts, certainties, routines. Their markets and their little disputes. Even as the cold thickened around them, they clung to the familiar warmth of denial.

Some whispered, in those last days, that this winter was unlike the others. They were correct, though far too late in being so. Winter had not merely arrived. It had awakened.

Perhaps that is why I write this last entry. Not for men, for there are none left to read it. But for myself, to pretend that I once belonged to a world that believed in reason.

My hands grow stiff. My breath smokes and then fades. The ink congeals. My heart slows. I understand, now, that I am the last. The last to think, to fear, to remember. When I fall, the world of men ends.

They are at the door.

I can feel the cold fingers already pressing into my bones, hollowing out my bones one breath at a time. There is no pain. Pain belongs to the living. Soon I will stand again, pale and silent, and whatever thoughts once lived behind these eyes will scatter like snow in a hard wind.

These are my dying words.

No human will ever read them.

No maester will stumble upon these scrolls. No child will whisper these lines as bedtime fright. No king will consult them for counsel. The last eyes capable of understanding this script are the ones growing dim even as I write.

And when I rise again, I will not remember the warnings I gave, nor the truth they carried, nor the world that ignored them until it was far too late.

Winter has come, and there is no one left to heed it.