Loan reminder voicebot for NBFCs: a design built on RBI’s fair-practice rules

A loan reminder voicebot for an NBFC has to do more than say “your EMI is due”. In November 2025 RBI consolidated its NBFC conduct rules into new directions, and several of them decide what a reminder or recovery call may say, when it may be made and who answers for it. This guide maps each stage of a loan, from the due date to SMA and NPA, to the rules that apply and the voicebot behaviour that follows from them.

By Vocora team · Published 9 November 2026

This is a product design guide, not legal advice. Paragraph numbers refer to the RBI directions linked in Sources as read in November 2026; check the current versions and your board-approved policies.

The rules that shape a reminder call

Rule (RBI NBFC directions, 2025)	What the voicebot does
All communications to the borrower in the vernacular or a language the borrower understands (Responsible Business Conduct, para 10)	Calls and messages in the borrower’s recorded language; switches when asked
No undue harassment in recovery, such as persistently bothering borrowers at odd hours; staff trained to deal with customers appropriately (para 20)	Attempt caps per day and per cycle; polite, scripted wording only
Reminders for non-compliance with material terms must state the applicable penal charges; any levy and its reason must be communicated (para 30(7))	Reads the penal charge from the loan record as a fact, never as a threat
No intimidation, threatening or anonymous calls, persistent calling, or calls before 8:00 a.m. or after 7:00 p.m. for recovery of overdue loans; no false or misleading statements (para 100)	Hard calling window for overdue calls; identifies the NBFC; no legal-action language
Microfinance: persistent calling, or calls before 9:00 a.m. or after 6:00 p.m., are harsh recovery methods; a dedicated recovery grievance mechanism (paras 91–92)	Tighter window for microfinance books; grievance route offered on every call
Agents trained on hours of calling, privacy and conveying correct terms; telemarketers registered as TRAI requires (paras 98, 101)	Vendor’s scripts, numbers and data access approved and documented

For a broader look at reminder calls by any lender, see our loan and EMI reminder voicebot guide. This page goes deeper for NBFCs.

Reminder stages mapped to overdue and SMA dates

RBI’s asset-classification directions for NBFCs tie each stage to the day-end process. An account is flagged overdue as part of the day-end process for the due date. RBI’s own illustration: if a loan due on 31 March is not paid, it is overdue on 31 March, tagged SMA-1 on 30 April after 30 days continuously overdue, SMA-2 on 30 May, and NPA on 29 June if it is still unpaid. The loan agreement must state the due dates and give examples of these classification dates, and the borrower must be told at sanction.

Stage	Call type	Voicebot	Your team
Before the due date	Service reminder	Due date, amount and official payment options; asks if the borrower expects any difficulty	Calls back anyone who says they may miss it
Due date passes unpaid (overdue)	Reminder for non-compliance	Explains the missed payment, states the applicable penal charge from the loan record, shares how to pay	Handles disputes and “already paid” cases
Overdue up to 30 days	Recovery of an overdue loan	Only within the 8 a.m.–7 p.m. window (tighter for microfinance), within attempt caps; records the reason and a promise date	Reviews hardship and restructuring requests
SMA-1 and SMA-2	Recovery, higher risk	Fewer, well-spaced calls; offers a callback from a named team; can explain what SMA means, as in your consumer education literature	Owns the case; decides on field visits or agencies under policy
NPA and beyond	Collections and recovery	Stops, unless your policy assigns it a narrow task such as confirming a scheduled visit	Recovery process, agencies and legal steps

The exact number of attempts and the wording come from your board-approved policies. RBI’s rules set the limits; they do not prescribe a cadence.

Explaining SMA and NPA on a call

RBI asks NBFCs to place consumer education literature on their websites explaining, with examples, the date of overdue and SMA and NPA classification and upgradation, and to have front-line officers educate borrowers about these concepts at sanction, disbursal and renewal. A voicebot can reinforce that, in plain words and the borrower’s language:

Illustrative wording, to be approved by your compliance team:

Bot: “Aapki 5 tarikh ki EMI abhi tak receive nahi hui hai. Loan agreement ke hisaab se is par [penal charge] lagta hai. Agar payment mein dikkat hai, main aapko branch team se connect kar sakti hoon. Aap payment ke official options WhatsApp par bhi dekh sakte hain.”

The bot states the charge because RBI requires it, but it does not frighten, does not mention credit scores or legal action to pressure, and offers a person.

The vendor is your responsibility

RBI’s outsourcing directions for NBFCs are blunt: outsourcing does not diminish the NBFC’s obligations, and the NBFC is responsible for the actions of its service providers, including recovery agents, and for the confidentiality of customer information they hold. For a voicebot vendor this means:

Need-to-know data. Share only the fields the call needs: name, loan ID, due date, amount, language and branch. RBI asks that service-provider access to customer information be limited to what the outsourced function requires.
Records you can audit. Recordings, transcripts and outcomes must be available to you and, under the directions, to RBI.
Grievances stay with you. Responsibility for redressing grievances about outsourced services rests with the NBFC. Every call should offer your grievance route, and complaints should reach your Grievance Redressal Officer’s queue.
Board review. The directions ask boards to review compliance with the Fair Practices Code and the grievance mechanism periodically. Voicebot outcomes, complaints and opt-outs belong in that review.

Numbers and WhatsApp

TRAI has directed RBI-regulated entities to move service and transactional calls to 1600-series numbers in phases; the deadlines for NBFCs ran from February to March 2026. Reminder calls should come from your 1600-series number. For background, see DLT registration and the 1600 series.

On WhatsApp, a neutral reminder about the borrower’s own account fits Meta’s Utility category. Anything that promotes a new product, such as a top-up loan, is Marketing and must not be mixed into a reminder. Copy-ready wording is in WhatsApp payment reminder templates.

Hard limits we build into NBFC scripts

Speak only to the borrower; never discuss the loan with family, referees or employers.
Separate calling windows for overdue calls and for microfinance books, enforced by the dialer, not the script.
State the NBFC’s name at the start and say the call may be recorded.
Read penal charges and dues from the loan record; never estimate.
No threats, shaming or misleading statements about the consequences of non-payment.
No OTPs, PINs, card numbers or Aadhaar, ever.
Hardship, disputes, “already paid” and complaints go to a person.

How Vocora sets it up for an NBFC

01
Stage feed from your LMSDue, overdue, SMA flag, penal charge, language and branch, refreshed after day-end
02
Policy into rulesWindows, attempt caps, wording per stage and escalation, signed off by compliance
03
Call and confirmVoice AI calls; WhatsApp AI sends the official payment details
04
Outcomes and audit trailWill pay, paid, hardship, dispute or complaint, with recordings, back to your systems

See the financial services playbook for the wider lending workflow, and DPDP and call recordings for how to handle borrower data.

What to measure

Share of borrowers reached before the due date, by language and branch
Accounts that become overdue among reminded borrowers, against your earlier cycles
Flow from overdue to SMA-1 and SMA-2, against your earlier cycles
Calls blocked by the calling-window rule, which should be the dialer doing its job
Complaints, opt-outs and grievance tickets linked to calls

Hear a reminder call demo Contact us · +91 98041 82483

FAQ

What is a loan reminder voicebot?

It is a voice agent that calls borrowers about their own loan account: before an instalment is due, on a missed payment and, under your policy, while an account is overdue. It states the facts from your loan system, records the borrower’s answer, sends the official payment details and routes difficulty, disputes and complaints to your staff.

What calling hours apply to NBFC recovery calls?

RBI’s Responsible Business Conduct Directions, 2025 say an NBFC and its agents must not call a borrower before 8:00 a.m. or after 7:00 p.m. for recovery of overdue loans, or call persistently. For microfinance loans a separate rule treats persistent calling and calls before 9:00 a.m. or after 6:00 p.m. as harsh recovery methods.

Does a reminder call have to mention penal charges?

Under the same directions, whenever an NBFC sends a reminder for non-compliance with material loan terms, it must communicate the applicable penal charges, and any levy of penal charges must be communicated with the reason. State them as facts from the loan agreement, never as a threat.

In which language should the voicebot speak?

RBI’s directions say all communications to the borrower shall be in the vernacular language or a language the borrower understands. Store each borrower’s language in your loan system and use it for calls and WhatsApp messages.

Is the NBFC responsible for what a voicebot vendor does?

Yes. RBI’s outsourcing directions say outsourcing does not diminish the NBFC’s obligations, that it is responsible for the actions of its service providers including recovery agents, and that responsibility for customer grievances about outsourced services stays with the NBFC.

How is this different from your EMI reminder voicebot guide?

Our EMI reminder guide covers the basic reminder cycle for any lender. This one is for NBFCs: it maps each call to RBI’s overdue and SMA stages and to the 2025 NBFC directions on fair practice, penal charges, language, recovery conduct, outsourcing and grievances.

How do we start?

Book a free 15-minute demo, WhatsApp +91 98041 82483, or email [email protected].

Sources

EMI reminder voicebot · Financial services · Voice AI · WhatsApp AI · Contact