Liability depends on what caused the transaction, when you reported it, and whether the card issuer is covered by the relevant Reserve Bank of India (RBI) directions. Under the RBI’s 6 July 2017 customer-protection circular, a bank bears the loss when its own fraud, negligence or deficiency caused the unauthorised transaction. A customer can also have zero liability for a third-party breach when neither the bank nor the customer was at fault and the customer reports the transaction within three working days of receiving the bank’s transaction communication.
If the customer’s negligence contributed—for example, by sharing payment credentials—the customer bears losses up to the time of reporting, while the bank bears subsequent losses. For a qualifying third-party breach reported after four to seven working days, liability is limited to the transaction value or the prescribed cap, whichever is lower. If the report comes later than seven working days, the bank’s board-approved policy determines the result.
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These are not blanket refund rules for every disputed charge. The issuer category, cause of the breach, evidence and reporting time all matter.
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The 2017 RBI circular distinguishes among bank responsibility, customer responsibility and an unauthorised transaction caused by a third party. The reporting windows below apply to the specified third-party-breach situation, where neither the bank nor the customer is at fault.
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| Cause of the unauthorised transaction | When the customer reports | Customer’s position |
|---|---|---|
| Bank fraud, negligence or deficiency | Any reporting time | Zero liability. The bank bears the loss. |
| Third-party breach; neither bank nor customer at fault | Within three working days of receiving the bank’s transaction communication | Zero liability. |
| Customer negligence, such as sharing payment credentials | Until the customer reports the transaction | The customer bears losses up to reporting. The bank bears losses after reporting. |
| Third-party breach; neither bank nor customer at fault | After four but within seven working days | Liability is capped at the transaction value or the applicable prescribed amount, whichever is lower. |
| Third-party breach; neither bank nor customer at fault | Later than seven working days | The issuer’s board-approved policy applies. |
The bank—not the cardholder—has the burden of proving customer liability in an unauthorised electronic banking transaction. That principle is stated in paragraph 12 of the RBI’s 6 July 2017 circular.
Which RBI instrument covers your credit card?
The central customer-protection framework is the RBI circular titled “Customer Protection – Limiting Liability of Customers in Unauthorised Electronic Banking Transactions,” dated 6 July 2017. Its annex contains revised instructions for Scheduled Commercial Banks and says that some earlier credit, debit and prepaid-card operating instructions are superseded.
Credit-card issuers are also governed by the RBI’s Master Direction – Credit Card and Debit Card – Issuance and Conduct Directions, 2022. The consolidated direction cited here was updated on 7 March 2024. Its credit-card provisions apply to scheduled banks, subject to the exclusions stated in the direction, and to all NBFCs operating in India. The direction requires issuers to maintain 24×7 reporting and card-blocking channels and refers issuers to the customer-protection circular as updated from time to time.
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Because the two instruments have different wording and coverage, identify the issuer before applying a rule. Do not assume that the 2017 annex, viewed in isolation, is a universal rule for every card provider. The card issuer’s terms and the applicable RBI direction still have to be read together.
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How the reporting deadlines are counted
The three-day, four-to-seven-day and beyond-seven-day bands are measured from the date you receive the bank’s transaction communication, not from the date you happen to notice the charge later. The date of receipt is excluded. The days are working days according to the working schedule of your home branch.
For example, if an alert arrives on a Monday, the first working day for this calculation is the next working day, subject to the home branch’s working calendar. A weekend or branch holiday does not count as a working day. Keep the alert itself so the receipt date can be established.
These bands do not convert every late report into automatic customer liability. They are specific to the third-party-breach category in the RBI framework. If the bank’s own fraud, negligence or deficiency caused the transaction, the bank’s responsibility is not removed merely because the customer reported it later. If the customer’s negligence caused the loss, the customer’s exposure runs only up to reporting, with the bank responsible for later losses.
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- Contact the issuer immediately. Use the bank’s phone, internet-banking, mobile-app or other designated 24×7 channel to report the transaction. Ask the issuer to block the card and any affected payment facility. RBI directions require channels that operate on a 24×7 basis and allow the customer to initiate card blocking.
- State that the transaction is unauthorised. Give the transaction date, amount, merchant description and the last four digits of the card. If more than one charge is disputed, list each one separately.
- Obtain an acknowledgement or complaint reference. Record the exact date and time of your call, message or online submission. Save confirmation emails, screenshots and the alert showing when the bank communicated the transaction.
- Change exposed credentials. If you suspect that a password, card PIN, one-time password or other credential was exposed, follow the issuer’s instructions for replacement and account security. Do not send credentials to anyone claiming to investigate the fraud.
- Notify the issuer of further attempts. Once a report is made, ask how the bank will prevent additional unauthorised transactions and monitor the account for new entries.
- Continue the written record. Keep the statement entry, complaint correspondence, replacement-card confirmation and any police or cybercrime report you choose to make. The record helps establish both the nature of the breach and the reporting time.
Banks must take immediate steps to prevent further unauthorised transactions after receiving a report. Their alert-delivery and customer-response systems are expected to record the date and time, so your own records should match those timestamps as closely as possible.
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Reversal, investigation and the 90-day limit
When the case falls within zero or limited liability under the RBI framework, the bank must provide a shadow reversal within 10 working days after notification. The bank cannot wait for an insurance claim to be settled before making that temporary credit.
The issuer must investigate the complaint and establish whether the customer has any liability within its board-approved timeline. The RBI circular caps that process at 90 days. If the bank cannot resolve the complaint or determine liability within 90 days, the circular requires applicable compensation to be paid immediately.
A credit-card customer must not be burdened with additional interest while an eligible unauthorised-transaction claim is being handled. Keep checking the statement to ensure that disputed amounts and related interest are treated consistently with the issuer’s investigation outcome.
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When customer negligence changes the result
Sharing payment credentials is the clearest example given in the RBI framework of customer negligence. In that situation, the customer bears the loss occurring before the report. Once the customer has notified the bank, losses arising afterward are borne by the bank under the circular.
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The bank still has to establish that customer liability exists. A disputed charge is not automatically proof that the customer was negligent, and a customer’s failure to recognise a merchant name is not, by itself, proof of credential sharing. Ask the issuer to identify the basis on which it says the customer caused or enabled the transaction.
- Preserve the original transaction alert and the statement line.
- Keep the complaint reference and the time the issuer received it.
- Write down whether you disclosed any card, login or payment credential and to whom.
- Record whether the card was in your possession and whether you had already reported loss or compromise.
- Save replacement-card and card-blocking confirmations.
- Keep any relevant messages, emails or device-security notifications that show when an account may have been compromised.
Do not alter screenshots or delete messages. If a document is unavailable, tell the issuer when and how you tried to obtain it rather than guessing at a date.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What a bank can and cannot assume from a late report
A late report affects the third-party-breach bands, but it does not make every transaction the customer’s responsibility. For a report within three working days, the qualifying third-party scenario carries zero liability. A report in the four-to-seven-working-day band carries the lower of the transaction value and the applicable prescribed cap. After seven working days, the issuer’s board-approved policy governs.
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The issuer should therefore identify three facts in its decision: who caused the breach, when the bank’s communication was received, and when the customer reported it. If any of those facts are disputed, request the bank’s recorded timestamps and the reason it placed the case in a particular liability category.
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If the issuer does not resolve the complaint
First use the issuer’s published grievance-escalation procedure and retain proof of each escalation. Ask for a written decision that states the transaction category, the evidence relied on, the dates used for the reporting calculation and any amount attributed to you.
If the issuer still does not resolve the matter, you may consider the RBI Integrated Ombudsman route when the complaint meets the scheme’s eligibility requirements. The sources establishing the rules above do not set out the Ombudsman scheme’s current filing criteria or timelines, so confirm those requirements directly before filing. An Ombudsman complaint does not replace the need to report the transaction promptly to the card issuer.
Unsolicited credit cards are a separate issue
The RBI’s 7 March 2024 FAQ says a card issuer must obtain prior and explicit consent before issuing a credit card. If a customer receives an unsolicited card and does not activate it with consent, the issuer must close the account without cost within seven working days after seeking confirmation.
This is a rule about an unsolicited, unactivated card account. It is not a substitute for analysing liability for an unauthorised transaction on an existing card. If an unsolicited card has been used or an account has been opened without consent, report that event immediately and ask the issuer to block and close the account while recording your complaint.
Practical decision framework
- Identify the issuer. Check whether the card was issued by a scheduled bank covered by the 2022 directions or by an NBFC operating in India, and review any stated exclusions.
- Classify the cause. Ask whether the evidence points to bank fraud, negligence or deficiency; customer negligence; or a third-party breach with neither side at fault.
- Fix the timeline. Establish when the bank’s transaction communication was received, excluding that date, and count working days using the home-branch schedule.
- Apply the matching consequence. Use the zero-liability, limited-liability or board-policy rule that corresponds to the cause and reporting band.
- Check the process protections. Confirm that the card was blocked, a complaint reference was issued, a shadow reversal was made within 10 working days where applicable, and the investigation stayed within the 90-day maximum.
- Challenge unsupported attribution. If the bank says you are liable, request the evidence and the recorded dates because the burden of proving customer liability rests with the bank.
The most protective step is also the simplest: report the charge and block the card immediately, then preserve the timestamps. Waiting can move a qualifying third-party case from zero liability into a capped or policy-based category, while a prompt report limits losses in a case involving customer negligence.
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