Banking for All: RBI's Path to Inclusion

Introduction

Accessibility is no longer optional. In April 2025, the Supreme Court declared that digital access is a fundamental right. At the center of the case was India’s digital KYC process. As we know, this has now become essential for opening bank accounts, buying SIM cards, accessing pensions, insurance, securities, and even government benefits.

The Court found that current steps shut out people with blindness, low vision, or facial disfigurement. This violated Article 21 of the Constitution and the Rights of Persons with Disabilities Act, 2016.

At its end, the RBI has already been proactive in enabling effective financial access to all citizens. The message is now clear: digital inclusion is a constitutional and regulatory duty. For lenders, this is not just about compliance. It is also a chance to expand reach, build trust, and lead in inclusive finance.

Context: Why This Matters

Over the past decade, financialization has been a key driving force of the growth of the Indian economy. At its core has been inclusion, with ambitious efforts like the PM Jan Dhan Yojana being key in expanding basic banking services to the underserved urban poor and rural populations.

As we continue to expand on the tech frontiers in finance, with activities like KYC, loan applications and management being done digitally, accessibility concerns have risen again.

Digital KYC, which has become the backbone of India’s financial system, has hardly been inclusive of the millions of Indians with disabilities. For example, eye-blinking checks blocked acid attack survivors and people with eye injuries. Selfie uploads and face recognition left people with blindness dependent on others.

In a similar vein, lending documentation and interfaces not being available in vernacular languages has been deeply problematic for the vast rural, urban poor and MSME populations who are usually only literate in their own regional language.

The Supreme Court’s ruling reset the rules: accessibility is no longer a choice. It is a constitutional guarantee.

RBI’s Proactiveness on Inclusion

The Court’s April 2025 ruling gave binding directions to regulators and service providers of which a few key ones include:

• Accessibility Standards: All KYC apps, websites, and devices must meet WCAG 2.1 and Indian accessibility norms.

• Alternative Verification: Liveness checks cannot rely only on blinking. Voice recognition, facial movements, OTP verification, and thumb impressions must be supported.

• Human Review: Auto-rejected KYC applications must be checked manually by trained officers.

• Customer Records: KYC/customer forms must capture disability type and percentage so services can be tailored.

• Inclusive Communication: KYC processes and notifications must support sign language, captions, audio descriptions, Braille, easy-to-read formats, and voice-enabled services.

Leading from the front, in August 2025, the RBI issued the 2nd Amendment to its KYC Directions (2016). It built accessibility into law. Key changes included:

• Persons with Disabilities are now directly named in the KYC Directions and hence accessibility needs to be a part of the policy.

• No KYC application may be rejected without proper reasoning, which needs to be documented.

• Liveness checks cannot exclude people with special needs.

• Aadhaar Face Authentication is recognized as an extra option.

The RBI has actually been proactive in the matter of inclusion. In April 2025, it mandated that the Key Fact Statements (KFS) had to be provided in a language understood by the borrower. This was not just for the documents but also for the customer journey portals/interfaces and customer communication. The intent is to make loan and banking processes inclusive for people who are literate in only their own languages.

Strategic Implications for Lenders

For banks, NBFCs, fintechs, and other financial institutions, the immediate job is to comply. But the bigger story lies in the strategic impact.

• Expanding the Market: The traditionally overlooked markets like the rural and the disabled form a massive opportunity for forward-looking lenders. Inclusive KYC and vernacular tech lowers barriers, opening a new channel for growth.

• Trust and Brand Equity: Early movers will stand out as champions of customer experience through inclusion. In a sector built on trust, accessibility can be a strong differentiator. The leaders will go above and beyond the current scope to better serve other excluded market segments as well.

• ESG and CSR Alignment: Accessibility ties directly to the “Social” pillar of ESG. Regulators and investors expect disclosures on inclusivity. Accessible lending technology positions lenders ahead of global standards.

• Better Credit Quality: Inclusive processes reduce disputes and onboarding failures. That translates into lower support and legal costs, stronger repayment patterns and fewer compliance-driven NPAs.

• Growth Lever, Not Burden: What begins as compliance can become a growth driver. The institutions that invest today will not just be safe from penalties - they will also capture tomorrow’s inclusive lending opportunities.

  
  

How OneFin Can Help

OneFin is ready for this shift. As lenders adapt, we provide the tools to move fast, scale safely, and embed accessibility in financial services.

• Auto-Vernacular Translation: Automated translation of the user journey in 9 Indian languages to show the information required to the user in their own language.

• Configurable KYC Workflows: Support for multiple KYC modes with fallback options available as needed.

• API-First Infrastructure: Add new features like Aadhaar Face Authentication without disruption.

• End-to-End Lending Suite: Origination, management, and collections built with compliance and inclusion in mind.

• Proven Scalability: Over 16 lakh loans processed and 100 million API calls annually.

Our Auto-Vernacular Translation feature has been developed in the true spirit of the guidelines. It will help backoffice staff, especially in rural areas, to be able to see their LOS / LMS in their regional language. That would help them serve the end customers better.

As India continues to build out the vernacular ecosystem with a massive focus on Indic AI and LLMs, we are prepared to lead on that mission. Expanding the market for financial services to the millions that are still linguistically excluded will drive the next phase of economic growth.

Conclusion

The Supreme Court has reset the rules of India’s digital economy: accessibility is now a fundamental right. RBI’s directions and amendments mark the first step in enforcement, and other regulators will follow.

For lenders, the implications are clear. Compliance is unavoidable, but those who go further - embedding accessibility into their processes and products - will win on trust, customer satisfaction, and growth.

With OneFin’s modular, API-driven platform, lenders can act quickly, scale securely, and build for an inclusive future. To know more, schedule a Demo here.