India

RBI FREE-AI

Framework for Responsible and Ethical Enablement of Artificial Intelligence (FREE-AI) Committee Report

An RBI-appointed committee's blueprint of 7 principles and 26 recommendations for safe, responsible AI use by banks, NBFCs and other regulated entities.

VoluntaryFrameworkDevelopers and deployers
Regulator
Reserve Bank of India (FREE-AI Committee)
Adopted
13 Aug 2025
In force
Not yet, or no single date
Sectors
Financial services
Penalties
None stated. The report makes recommendations; it is not an RBI Direction. It proposes that REs stay liable for customer losses, with tolerant supervision for first-time lapses where safeguards were followed.
Last verified
19 Oct 2026Official source

Summary

  • RBI set up an expert committee (chaired by Prof. Pushpak Bhattacharyya, IIT Bombay) which published the FREE-AI report on 13 Aug 2025.
  • It rests on 7 Sutras (principles): Trust is the Foundation; People First; Innovation over Restraint; Fairness and Equity; Accountability; Understandable by Design; Safety, Resilience and Sustainability.
  • It makes 26 recommendations under 6 pillars: Infrastructure, Policy, Capacity (innovation side) and Governance, Protection, Assurance (risk side).
  • Recommendations 14 to 25 are the ones that land on regulated entities (REs): board-approved AI policy, data and model governance, product approval, consumer protection, cyber, red teaming, AI BCP, incident reporting, AI inventory, audit and disclosures.
  • Status (as of 2026-10-19): still a committee report. RBI has not issued binding Directions implementing it. The closest follow-up is RBI's draft model risk guidance of 24 Jun 2026, which cites FREE-AI as background and covers AI/ML models; it was not final at the time of checking.

Who it applies to

  • Entities regulated by RBI: banks, NBFCs, payment system operators, all-India financial institutions; FinTechs are named in some recommendations (sandbox, incident reporting).
  • Many recommendations are addressed to regulators and industry bodies (Recs 1 to 9, 11 to 13, 26), not to REs.
  • Not extraterritorial. A foreign AI vendor is reached only indirectly, through the RE's third-party and outsourcing obligations.

Key dates

  1. RBI announces the committee in its Statement on Developmental and Regulatory Policies
  2. FREE-AI Committee constituted
  3. Committee report published on rbi.org.in (Press Release 2025-2026/902)
  4. RBI issues draft Guidance on Regulatory Principles for Model Risk Management, citing FREE-AI as background (Press Release 2026-2027/528)
  5. Comment deadline for the draft model risk guidance
Full date record
Date Event
2024-12-06 RBI announces the committee in the Statement on Developmental and Regulatory Policies
2024-12-26 Committee constituted
2025-08-13 Report released (Press Release 2025-2026/902)
2026-06-24 RBI issues draft Guidance on Regulatory Principles for Model Risk Management (Press Release 2026-2027/528), citing FREE-AI
2026-07-24 Comment deadline on the draft model risk guidance; no final version found as of 2026-10-19

Penalties and enforcement

  • No penalties in the report. It is a set of recommendations.
  • Recommendation 8 proposes a graded liability approach: REs stay liable for customer losses, but supervisors should go easy on a first-time lapse if the RE followed safeguards like incident reporting, audits and red teaming. That leniency should not apply to repeat breaches, gross negligence or failure to fix issues.
  • Para 4.4.64: where a customer is harmed, the RE should compensate; reporting an incident should not by itself trigger penal action if corrective steps are timely.
  • Enforcement in practice would come later, through RBI Directions or guidance (for example the draft model risk guidance) and supervisory inspection.

What it means for an Indian company

  • Banks, NBFCs, payment companies: treat Recs 14 to 25 as the checklist RBI supervisors will reference. Most items reappear in the June 2026 draft model risk guidance (board-approved framework, inventory, red teaming, customer AI disclosure, human switch, kill switch).
  • AI vendors selling to BFSI: expect customers to ask for model documentation, red-team results, incident cooperation and audit rights, because REs remain accountable for third-party AI.
  • FinTechs partnering with REs: your AI features will be pulled into the RE's product approval and inventory.
  • It overlaps heavily with ISO 42001; an AIMS covers much of the governance pillar.

Obligations

Recommendations are addressed to REs unless noted. "Para" numbers are from Chapter 4 of the official report.

Showing 30 of 30
IDObligationReferenceApplies toControls
RBI-FREEAI-01Adopt a board-approved AI policy covering governance, accountability, risk appetite, safeguards, auditability, consumer protection, AI disclosures, model lifecycle and liabilityRec 14; Para 4.4.44Deployer
RBI-FREEAI-02Classify AI use cases as low, medium or high risk in that policy, and review the classification periodicallyRec 14; Para 4.4.44Deployer
RBI-FREEAI-03Give the Risk Management Committee (or similar) ownership of AI risk; consider a cross-functional AI adoption committeePara 4.4.45Deployer
RBI-FREEAI-04Bring staff use of third-party and off-the-shelf AI tools (such as GenAI apps) under the internal AI policyPara 4.4.46Deployer
RBI-FREEAI-05Keep the internal AI policy aligned with national AI governance and regulatory frameworksPara 4.4.46Deployer
RBI-FREEAI-06Build AI governance competence at Board and C-suite level and run ongoing AI training for staff who use AI (two to three year glide path for AI expertise)Rec 10; Paras 4.4.35 to 4.4.36Deployer
RBI-FREEAI-07Govern AI data across its lifecycle (collection, access, use, retention, deletion) in line with the DPDP ActRec 15; Para 4.4.47Both
RBI-FREEAI-08Use data that is relevant, fairly representative and ethically sourced; keep sensitive data inside controlled environments when using external or open-source modelsPara 4.4.47Both
RBI-FREEAI-09Govern models from design to decommissioning, with documentation of objectives, design, context and benchmarksRec 16; Para 4.4.48Both
RBI-FREEAI-10Validate and periodically test all models, built in-house or bought, before and during useRec 16; Para 4.4.48Both
RBI-FREEAI-11Monitor for drift, degradation, bias and unexplained behaviour, with defined fallbacksRec 16; Para 4.4.48Deployer
RBI-FREEAI-12Before using autonomous AI, set safeguards, testing protocols and SOPs; define what AI may do alone; keep human oversight for medium and high risk tasksRec 16; Para 4.4.49Deployer
RBI-FREEAI-13Put every AI-enabled product through product approval, with AI-specific checks (fairness, bias, understandability, cyber) by a team independent of the developersRec 17; Paras 4.4.50 to 4.4.51Deployer
RBI-FREEAI-14Adopt a board-approved consumer protection framework for AI built on transparency, fairness and recourseRec 18; Para 4.4.53Deployer
RBI-FREEAI-15Tell customers when they are dealing with AI and always offer a switch to a humanPara 4.4.54Deployer
RBI-FREEAI-16Provide grievance redress for AI interactions and decisions, with easy escalation to human staffParas 4.4.54 to 4.4.55Deployer
RBI-FREEAI-17Run AI only through verifiable channels (for example 1601-series numbers for voice, watermarked or clearly labelled digital interfaces); never falsely claim AI usePara 4.4.54Deployer
RBI-FREEAI-18Run awareness campaigns on safe AI use, customer rights and how to complainRec 18; Para 4.4.55Deployer
RBI-FREEAI-19Identify AI-specific security risks (adversarial attacks, data poisoning, model manipulation) before deployment and keep assessing after go-liveRec 19; Paras 4.4.56 to 4.4.57Both
RBI-FREEAI-20Be able to shut an AI system down instantly if it risks significant harmPara 4.4.58Deployer
RBI-FREEAI-21Red team AI: at least half-yearly for medium and high risk, at least pre-deployment for low risk, plus trigger-based runs; document findings for audit and supervisorsRec 20; Para 4.4.60Both
RBI-FREEAI-22Extend BCP to AI failures (including silent degradation), with fallbacks, drills and sample human checks of AI decisionsRec 21; Paras 4.4.61 to 4.4.62Deployer
RBI-FREEAI-23Record and report AI incidents promptly through the channel regulators set (indicative form in Annexure VI); compensate harmed customersRec 22 (REs and regulators); Paras 4.4.48, 4.4.63 to 4.4.64Deployer
RBI-FREEAI-24Keep an AI inventory (models, use cases, target groups, dependencies, risk tier, grievances), update it at least half-yearly, and make it available to supervisorsRec 23; Paras 4.4.68 to 4.4.69Deployer
RBI-FREEAI-25Run a risk-based AI audit covering input data, model and algorithm, and outputs, aligned to the board-approved risk tiersRec 24(a); Paras 4.4.72 to 4.4.74Deployer
RBI-FREEAI-26Commission independent third-party audits for high-risk or complex AIRec 24(b); Para 4.4.74Deployer
RBI-FREEAI-27Audits should confirm stop, pause or unwind mechanisms, an AI BCP and human override for critical decisionsPara 4.4.74Deployer
RBI-FREEAI-28Review the AI audit framework at least every two yearsRec 24(c)Deployer
RBI-FREEAI-29Publish AI disclosures in the annual report and website (governance, use areas, consumer protection, complaints handled)Rec 25; Para 4.4.76Deployer
RBI-FREEAI-30Optionally use an industry AI compliance toolkit to benchmark fairness, transparency and robustness (voluntary; does not replace internal validation)Rec 26; Para 4.4.78Deployer

Evidence an auditor will ask for

  • Board resolution approving the AI policy, plus the policy itself (compare with the outline in Annexure V of the report).
  • Risk classification method and the current tier of each AI use case.
  • Committee charters or minutes showing who owns AI risk.
  • AI inventory export with the fields in Para 4.4.68 and a change log showing half-yearly updates.
  • Model documentation, validation reports and drift monitoring dashboards.
  • Product approval records for AI products, showing the independent evaluator.
  • Customer-facing screens or scripts that disclose AI and offer a human option.
  • Grievance logs tagged for AI, with resolution outcomes.
  • Red-team reports with dates, scope, findings and remediation.
  • AI BCP, fallback runbooks and drill results.
  • AI incident register and any reports filed.
  • AI audit plan, internal and third-party audit reports.
  • AI section of the annual report and website.
  • Training records for Board, senior management and staff.

Common mistakes

  • Calling FREE-AI "in force". It is a committee report; cite it as expected practice and watch for RBI Directions.
  • Writing an AI policy that never gets to the Board.
  • Leaving staff use of ChatGPT-style tools out of scope of the policy.
  • An inventory that only lists in-house models and skips vendor AI, or is never refreshed.
  • Red teaming only once before launch, even for high-risk models.
  • Chatbots that do not say they are AI or have no route to a human.
  • BCP plans that only cover outages and ignore silent model degradation.
  • Assuming a vendor's certificate shifts liability; the RE stays responsible.

Glossary

  • RE (Regulated Entity): a bank, NBFC or other body supervised by RBI.
  • Sutra: a guiding principle; the Sanskrit word means "thread".
  • Red teaming: deliberately attacking your own AI to find weaknesses before others do.
  • Model drift: a model getting less accurate because real-world data has shifted away from its training data.
  • BCP (Business Continuity Plan): the plan for keeping a service running when a system fails.
  • Autonomous AI: AI that can act (for example move money) without a human approving each step.
  • 1601 series: a phone number series the report names as a verified channel for AI voice interactions with customers.
  • EmTech Repository: a repository run by the Reserve Bank Innovation Hub that the report suggests expanding into a sector-wide AI register.

Key takeaways

  • A committee report, not a Direction: status is voluntary or expected practice until RBI issues rules.
  • 30 RE-facing obligations come from Recs 10 and 14 to 26; they read like an ISO 42001 plus AI security checklist.
  • RBI's June 2026 draft model risk guidance already carries several items forward (board framework, inventory, red teaming, AI disclosure, human switch, kill switch), so preparing now is low regret.

Official sources

This is general information, not legal advice. Last verified 19 Oct 2026 against the official source. Laws change; confirm the current position with qualified counsel before acting.

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