RBI Allows Banks to Delegate ATM Cassette Swap Monitoring to a Committee of Executives

Under a circular dated 1 October 2026, the Reserve Bank of India has partially modified the March 31, 2022 instructions on cassette swaps in ATMs. The Board may now delegate monitoring of the progress of implementation of cassette swap to a Committee of Executives of the bank. The change concerns the governance of the monitoring responsibility that was assigned to Boards in the 2022 circular.

What Changed?

Who Is Affected?

The circular is addressed to the Chairman, Managing Director or Chief Executive Officer of All Banks. The footnote ties the change to four sets of 2026 amendment directions: Reserve Bank of India (Commercial Banks-Governance), (Small Finance Banks-Governance), (Payments Banks-Governance) and (Local Area Banks-Governance) Amendment Directions, 2026. The source does not state any exemption, and it does not address entities outside "All Banks".

What Does the Circular Say?

The circular refers to RBI/2021-22/190 dated March 31, 2022, titled "Cassette - Swaps in ATMs". It then states, in partial modification to para 3 of that circular, that monitoring of the progress of implementation of cassette swap "may be delegated by the Board to a Committee of Executives" of the bank.

Three points of reading are worth noting:

• The wording is permissive. "May be delegated" gives the Board an option and does not require delegation.
• Only the monitoring limb of para 3 is addressed. The 2022 para 3 also required banks to set a Board-approved internal timeline and submit quarterly status reports. The 2026 circular does not mention those two requirements, so on its face they are not modified.
• "Committee of Executives" is not defined in the circular. The footnote points to the Governance Amendment Directions, 2026. Banks should check those directions for what the expression covers.

Background: The 2022 Cassette Swap Circular

The 2022 circular recorded that banks had earlier been advised to consider using lockable cassettes in their ATMs, swapped at the time of cash replenishment. The rollout was to be phased, covering at least one third of ATMs every year. The deadline for all ATMs had been March 31, 2021, was later extended to March 31, 2022, and was then extended to March 31, 2023 by the 2022 circular. The 2026 circular does not state any new deadline or comment on the status of the earlier one.

When Does It Apply?

Practical Implications

Editorial compliance recommendation: A bank choosing to use the delegation option should document the Board's decision and clearly record the Committee of Executives responsible for the delegated monitoring, subject to the bank's applicable governance framework. The 2026 circular does not prescribe a specific form or documentation format.

For compliance teams, the immediate issue is checking whether the Board's existing ATM cassette-swap monitoring arrangement and related terms of reference should be updated. The delegation is optional, so a bank may continue to retain the monitoring responsibility at Board level while complying with the applicable requirements of the 2022 circular as modified.

Compliance Checklist

The 2026 circular partially modifies para 3 of the March 31, 2022 circular. It does not prescribe a separate implementation checklist or documentation format. The items below are therefore editorial compliance suggestions for banks reviewing their governance arrangements.

Frequently Asked Questions

What did RBI change in the ATM cassette swap circular?

RBI advised that monitoring the progress of implementation of cassette swap may be delegated by the Board to a Committee of Executives of the bank. This partially modifies para 3 of RBI/2021-22/190 dated March 31, 2022.

Is the delegation mandatory?

No. The circular says monitoring "may be delegated", so the Board can delegate or continue to monitor the progress itself.

When does the change take effect?

A footnote to the circular states that the change is substituted with effect from October 1, 2026.

Which banks does the circular cover?

It is addressed to All Banks. The footnote refers to Governance Amendment Directions, 2026 for Commercial Banks, Small Finance Banks, Payments Banks and Local Area Banks.

Does the circular change the cassette swap deadline?

The 2026 circular does not specify a new deadline for cassette-swap implementation. The earlier RBI/2021-22/190 circular had extended the timeline for implementation of cassette swap in all ATMs to March 31, 2023. The 2026 circular does not state any new extension or revision of that timeline.

Do Board-approved timelines and quarterly status reports still apply?

The 2026 circular expressly modifies the monitoring component of para 3 by allowing delegation to a Committee of Executives. It does not mention the Board-approved internal timeline or quarterly status-report requirements contained in the 2022 circular. Those requirements should therefore be checked against para 3 of RBI/2021-22/190 and the current applicable framework rather than assumed to have been expressly restated by the 2026 circular.

CorpLawUpdates Analysis

CorpLawUpdates analysis: The 2026 circular makes a targeted governance change to the monitoring arrangement for ATM cassette-swap implementation. Its footnote refers to the Reserve Bank of India (Commercial Banks-Governance) Amendment Directions, 2026, the Small Finance Banks-Governance Amendment Directions, 2026, the Payments Banks-Governance Amendment Directions, 2026 and the Local Area Banks-Governance Amendment Directions, 2026. The source itself does not state that similar amendments have been made across other instructions.