Regulatory Analysis · India · BFSI

RBI Draft Model Risk Management Guidance: An AI Compliance Checklist for Indian Banks

RBI published its draft Guidance on Model Risk Management on 24 June 2026. The final circular is pending — but Indian banks should start mapping their AI portfolios to its requirements now. Here is a practical checklist.

What the draft guidance covers

The Reserve Bank of India published its draft Guidance on Model Risk Management on 24 June 2026, inviting comments from regulated entities. The guidance applies to banks and other RBI-regulated institutions that use models — including statistical models, machine learning models, and AI systems — for decision-making in areas including credit, fraud detection, liquidity management, and operational risk.

The draft guidance is structured around six pillars: model governance, model development, model validation, model implementation and use, ongoing monitoring, and model retirement. It draws on international best practice — particularly the Federal Reserve's SR 11-7 — while adapting requirements to the Indian banking context, including alignment with SEBI's AI governance expectations and the DPDP Act 2023.

Final guidance has not been published as of October 2026. Institutions should note that the draft is subject to change. However, the core requirements are unlikely to differ materially from international norms, and building governance structures against the draft is the right preparation posture. Waiting for the final circular before starting governance work is not a low-risk strategy.

Compliance checklist

Note: Based on RBI's draft Guidance on Model Risk Management (published 24 June 2026). Final guidance has not been issued. Requirements may change. This checklist is provided for planning purposes only and does not constitute legal advice.
Pillar 1 — Model Governance
RequirementEvidence requiredZytra module
Board-approved model risk policyPolicy document + board resolutionGovernance workflows
Model risk appetite defined by tier (Critical / High / Medium / Low / Minimal)Risk appetite statementRisk atlas — risk tiering
Senior management accountable for model riskNamed risk owner per modelAI asset registry — ownership
Model risk committee or equivalent bodyMeeting minutes with model approvalsEvidence ledger — committee sign-offs
Pillar 2 — Model Inventory & Development
RequirementEvidence requiredZytra module
Comprehensive model inventory — all in-scope modelsModel register with purpose, owner, risk tierAI asset registry
AI Bill of Materials (training data lineage, architecture, dependencies)AIBOM documentationAIBOM — Enterprise tier
Development documentation: objective, assumptions, data sources, limitationsModel card / development reportGovernance workflows
Pre-deployment risk assessmentRisk assessment recordAssessment engine
Pillar 3 — Model Validation
RequirementEvidence requiredZytra module
Independent validation before production deploymentValidation report by independent teamEvidence ledger — validation sign-off
Adversarial and stress testing for AI modelsTest results against adversarial inputsRed-team (Aval + FinProof B-01–B-14)
Fairness assessment for credit and customer-facing modelsBias/fairness test results (NIST MEASURE 2.11)Governance — fairness controls
Validation refreshed after material model changesRe-validation record with change logValidation tracking
Pillar 4 — Implementation & Use
RequirementEvidence requiredZytra module
Runtime guardrails on AI model outputsGuardrail block logs, policy trigger recordsAval guardrails
Approved use case documented and enforced at runtimeApproved scope vs. actual use recordsGovernance workflows
Human-in-the-loop for high-risk decisionsEscalation logs, human review event recordsAgent control room — human review
Output monitoring: model drift and degradationMonitoring dashboard and alert historyContinuous monitoring
Pillar 5 — Ongoing Monitoring
RequirementEvidence requiredZytra module
Performance monitoring post-deploymentMonthly / quarterly performance metricsContinuous monitoring
Periodic re-validation (minimum annual for Critical / High tier)Re-validation schedule and reportsGovernance workflows
Incident reporting: model errors, failures, adverse outcomesIncident register with root-cause analysisEvidence ledger
Regulatory reporting on model riskMRM committee report (board-submittable)Evidence export (PDF / OSCAL)
Pillar 6 — Model Retirement
RequirementEvidence requiredZytra module
Documented retirement process with decision rationaleRetirement decision recordGovernance workflows
Evidence retained post-retirement per RBI data-retention normsArchived model record setEvidence ledger — retained records
DPDP Act data deletion for personal data used in model trainingDeletion certificatePrivacy controls

Key dates and status

Draft published: 24 June 2026. Final guidance: pending publication.

Institutions should take three actions now, before the final circular lands:

Start the model inventory. The inventory requirement is certain regardless of final wording — every version of MRM guidance at every jurisdiction requires a complete model register. Begin cataloguing all AI and ML systems in production, including models you did not build (third-party models, vendor AI systems), against the six-pillar structure above.

Implement risk tiering. Classifying models as Critical / High / Medium / Low / Minimal aligns with both the RBI draft and SR 11-7. This tiering drives validation frequency, monitoring intensity, and evidence depth — decisions that should be made before an examination, not during one.

Build the evidence infrastructure. Retrofitting evidence collection after an inspection is significantly harder than building it as part of deployment. The evidence an examiner will ask for — board resolutions, validation reports, monitoring dashboards, incident registers — should be a byproduct of your governance process, not a manual exercise triggered by an examination notice.

Closing

The RBI draft guidance signals that model risk management for AI will be a regulatory priority in India. The institutions best positioned when the final circular lands are those treating the draft as actionable now — not as a preview to acknowledge and file.

Model risk is now AI risk. The checklist above is a starting point.

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Map your AI portfolio to RBI's requirements before the final circular.

Zytra's India regulatory pack covers RBI draft MRM Guidance, SEBI, and DPDP Act 2023 — out of the box.