The Reserve Bank of India ("RBI") recently introduced
the Master Directions – Reserve Bank of India (Credit
Information Reporting) Directions, 2025 ("Master
Directions"), subtly restructuring the legal architecture
governing India's credit information ecosystem. These
directions—though building upon the framework under the
Credit Information Companies (Regulation) Act, 2005
("CICRA") and the CIC Regulations, 2006—have led to
interpretational challenges for regulated entities, particularly
Specified Users.
Expanded Access to Credit Information
Traditionally, access to credit information was restricted to
'Credit Institutions' and 'Specified Users'.
However, under the new Master Directions, Credit Information
Companies ("CICs") are now permitted to share credit data
with entities beyond these defined categories. This inclusion,
while expanding the scope of data access, comes with heightened
compliance obligations.
