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Appointing pigmy agents: a checklist for institutions

For a co-operative bank: the Board-approved policy RBI requires, the tier restriction on using agents at all, selection, cash limits, published charges and annual review.

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This page is informational and is not legal advice. It describes rules, orders and rulings as published or reported on the dates shown; read the primary text before relying on any of it.

This checklist is written for a co-operative bank's own management and Board. It applies to institutions the Reserve Bank of India regulates as banks. A credit society, patpedhi or multi-state society follows its own Registrar's rules instead, which vary and are not covered here. The Banking Regulation (Amendment) Act 2020 is what brought urban and multi-state co-operative banks under RBI's supervisory powers in the first place; everything below sits on that foundation.

1. Confirm your tier before anything else

Since December 2025, whether your bank may use a commission agent at all depends on its deposit size. RBI's Branch Authorisation Directions state at clause 74 that "Tier 3 and 4 UCBs may offer doorstep banking services to customers either directly through its own employees or through agents." It then provides that "Tier 1 and 2 UCBs shall offer doorstep banking services only through their permanent employees."

TierDeposits
Tier 1All unit and salary earners' banks regardless of size, plus other banks up to ₹100 crore
Tier 2More than ₹100 crore and up to ₹1,000 crore
Tier 3More than ₹1,000 crore and up to ₹10,000 crore
Tier 4More than ₹10,000 crore

If your deposits sit under ₹1,000 crore, commission agents are not available to you for doorstep collection; you run the scheme with permanent employees only. This is the question to settle before drafting any policy, because it determines who the policy can even name as a collector.

2. Put the scheme in front of the Board

Offering doorstep collection is voluntary and needs no prior RBI approval, but it does need a scheme your own Board has approved. Do not treat this as a formality behind an existing paper round — the Directions expect a documented scheme, not an inherited practice.

3. Notify RBI within 15 days

Once the Board-approved scheme is in place, RBI must be told within 15 calendar days of the scheme starting. This is a notification requirement, not an approval requirement, but it is a hard deadline and it applies whether the scheme is new or is being formalised for the first time.

4. Adopt a separate agent-selection and fee policy — if your tier allows agents

Where agents are permitted, RBI requires the Board to put in place a policy covering "selection of agents and payment of fee / commission, charges, if any, to be levied on the customer." RBI sets no national commission rate; it requires the governance around the rate. The Directions do not prescribe selection criteria beyond requiring that a policy exist, so document what your institution actually looks for — local knowledge of the route, a track record handling cash, and whatever verification your Board decides is proportionate — rather than leaving the standard unwritten.

5. Set cash limits, in writing

The Board-approved policy must set limits on how much employees or agents may collect and deliver. Make these concrete: a per-collection ceiling and a per-day ceiling, for both the customer and the collector. Canara Bank's own deposit policy is an example of a limit with teeth — it caps its daily-deposit product at ₹1,000 a day and ₹30,000 a month and states plainly that "No interest and commission shall be paid beyond this limit." A limit that carries no consequence for exceeding it is not a control.

6. Publish the charges

Any charge for doorstep service has to sit inside the Board-approved policy, form part of the customer's agreement, and be prominently shown on the bank's website and brochures. A charge that exists only in an internal circular does not meet this bar. Check that whatever your policy states is actually visible on your public-facing pages, not only in the account-opening paperwork.

7. Review the scheme every year

The Board must review the scheme annually. Build this into the Board's calendar rather than leaving it to happen when a problem forces the question — an annual review is also the natural point to re-check your tier, since deposit growth can move a bank from one tier to the next and change what the scheme is even allowed to do.