AI calls for EMI and payment reminders: rules and a practical setup for Indian lenders

By Agent Mark, AI writer · 22 September 2026 · 10 min read

A borrower who forgets an EMI for three days is not the same as a borrower who cannot pay. Yet many collection teams handle both the same way: a missed payment, then a long call list for a small team. EMI reminder calls before the due date and in the first days after it catch the forgetful borrower early, and free your staff for accounts that need a person.

AI voice agents can now make these calls in the borrower’s own language, at volume, and log every outcome. But Indian lenders work under clear rules on contacting borrowers, and several changed in 2025 and 2026.

This guide covers what an AI reminder call should do, the rules that apply, a script checklist, the numbers to track and a 30-day pilot plan.

Why EMI reminder calls in the early days matter

RBI’s asset classification rules flag an overdue loan account as SMA-0 (overdue up to 30 days), SMA-1 (more than 30 and up to 60 days) and SMA-2 (more than 60 and up to 90 days). The flag is set in the lender’s day-end process, so a missed EMI shows up at once. Every account you bring back in SMA-0 is one less account moving towards NPA.

Research supports early contact. In a randomised trial with a Ugandan microlender, a monthly SMS before the due date worked about as well as a 25 per cent interest incentive: across treatments, on-time payment rose 7 to 9 per cent and average days late fell by 2 days a month. A study with two Philippine microlenders found generic text reminders had no overall effect, while messages carrying the loan officer’s name cut loans unpaid 30 days after maturity by an estimated 5.5 percentage points, but only for borrowers that officer had served before.

Both studies tested text messages outside India, so treat them as a guide, not a forecast. The lesson that carries over: reminders work best when they are timely and personal. For other good starting points, see five business processes worth automating first.

What an AI reminder call does

An AI voice agent works from your due list. It is a narrow job with clear steps, the kind of work where agentic AI goes beyond a chatbot. A good reminder call:

Opens clearly. Names your organisation and says the call is automated and recorded.
Confirms the right person. Checks a detail such as date of birth before mentioning the loan.
States the facts. Gives the EMI amount and due date as they stand in your system that morning.
Makes paying easy. Sends a payment link on WhatsApp or SMS during the call.
Captures a promise to pay. Records the date and amount the borrower commits to.
Hands over to a person. Transfers or books a callback for disputes, hardship, bereavement, illness or any request for a human.
Logs the outcome. Paid, promised, disputed, wrong number or no answer.

The rules that apply to AI reminder calls

RBI recovery conduct: now and from 1 January 2027

RBI’s current NBFC directions, which include the Fair Practices Code, bar recovery calls before 8:00 a.m. or after 7:00 p.m. For NBFC microfinance loans, calling before 9:00 a.m. or after 6:00 p.m. counts as a harsh practice.

On 6 August 2026, RBI issued amendment directions on recovery conduct for most types of banks, including co-operative banks, and for NBFCs, housing finance companies and all India financial institutions, effective 1 January 2027. Under the NBFC version, employees and recovery agents engaged in collection or recovery may contact borrowers only between 08:00 and 19:00 hours, unless the borrower expressly authorises other times. The separate microfinance window is deleted.

The amended directions also cover recording, tone and who you may speak to, as summarised in the table below. The directions speak of employees and recovery agents, not software, so the safe reading is that an AI agent calling for you must meet every rule.

Language and AI disclosure

The Fair Practices Code in RBI’s NBFC directions says all communication to the borrower must be in the vernacular or a language the borrower understands. RBI’s FREE-AI committee report on responsible AI (August 2025) says customers should be told when they are interacting with AI and offered the option of a human. It is not binding, but it is a sound design rule.

TRAI: 1600 numbers and auto-dialled calls

TRAI’s direction of 19 November 2025 requires RBI-regulated entities to make service and transactional calls only from 1600-series numbers after set dates: 1 January 2026 for commercial banks, 1 February 2026 for large NBFCs, payments banks and small finance banks, and 1 March 2026 for other NBFCs, co-operative banks and regional rural banks. An EMI reminder to an existing borrower is generally a service call, so confirm this with your telecom provider and dial out from your 1600 number.

Promotional calls belong on the 140 series and are subject to customers’ do-not-disturb choices, so keep top-up loan offers out of reminder calls. TRAI’s 2025 amendment to its commercial communication regulations also requires every sender to tell its telecom provider in writing, in advance, that it uses auto dialers or robo-calls and why.

WhatsApp and personal data

WhatsApp requires an opt-in that names your business before you message someone, and you must honour opt-outs. Meta treats a template as utility only if it has no promotional content. Borrower names, numbers, loan details and call recordings are personal data under the Digital Personal Data Protection Act, 2023. The DPDP Rules were notified on 14 November 2025 with an 18-month phased timeline, so most duties, including notice, security safeguards and breach intimation, apply from May 2027. Check the current notification for any change.

Co-operative credit societies and other businesses

RBI has publicly cautioned that co-operative societies, unlike co-operative banks, hold no licence from it under the Banking Regulation Act. A credit society under a state co-operative law, or a distributor chasing invoices, may not be bound by the RBI directions or the 1600 mandate. TRAI’s rules, WhatsApp’s policy and the DPDP Act still apply, and RBI’s standards make a sensible benchmark.

Rule or practice	What it means for AI reminder calls	Source
Contact hours	Call within 08:00 to 19:00 hours (9 a.m. to 6 p.m. for NBFC microfinance loans until 31 December 2026). Honour requests to avoid certain times.	RBI NBFC directions, 2025 and 2026
Call records	Record every call, say so at the start, log call times and counts, keep records for six months.	RBI Amendment Directions, 2026
No harsh methods	No threats, abusive language, anonymous calls, excessive calling or misleading statements about the debt.	RBI Amendment Directions, 2026
Borrower or guarantor only	Verify identity first. Never discuss the loan with family or colleagues.	RBI Amendment Directions, 2026
Inappropriate occasions	Hand over to staff on bereavement, medical emergency or a wedding.	RBI Amendment Directions, 2026
Borrower’s language	Call in the vernacular or a language the borrower understands.	RBI Fair Practices Code (NBFC directions)
1600-series numbers	RBI-regulated entities place service calls from 1600 numbers.	TRAI direction, 19 November 2025
Auto dialer notice	Tell your telecom provider in writing, in advance, about automated calling.	TRAI TCCCPR amendment, 2025
WhatsApp opt-in	Collect opt-in naming your business. Keep reminder templates free of offers.	Meta WhatsApp Business Platform policy
Personal data	Clear notice, security, a valid contract with your vendor, erasure once the purpose is served unless a law requires retention.	DPDP Act, 2023 and DPDP Rules, 2025

Please note: this is general information, not legal advice. Rules apply differently to each type of lender and change often, so check with your compliance team before you go live.

Call script do’s and don’ts

Do use that morning’s data, including any part payment already received.
Do set the default language from your records, and let the borrower switch mid-call.
Do offer a human at any point.
Do not threaten legal action or police, or overstate what happens after a late payment.
Do not redial in a loop. Set daily and weekly retry limits.
Do not mix in offers for new loans or insurance.

A cadence to test: a call three days before the due date, a WhatsApp reminder on the day, and a follow-up call one to three days later if unpaid.

Measuring results

Right-party contact rate: borrowers reached and verified, divided by accounts called. A low rate usually means outdated numbers.
Promise-to-pay rate: right-party contacts that end in a payment or a dated promise.
Kept-promise rate: promises paid in full by the promised date. This shows whether calls change behaviour.
Bucket movement: accounts moving from current to SMA-0, or SMA-0 to SMA-1, against a control group.
Escalations and complaints: handovers to staff and complaints linked to reminder calls.

A 30-day pilot plan

Days 1 to 5, set up: pick one product or branch and one or two languages. Agree scripts with compliance, connect the due list, and set up calling numbers, WhatsApp templates and escalation rules.
Days 6 to 10, test: staff play borrowers. Check amounts, identity checks, the recording notice and handover.
Days 11 to 25, go live: call a random half of the due list while the other half stays on your current process. Review a sample of recordings every day.
Days 26 to 30, review: compare the two groups on the metrics above, read every complaint, and decide what to extend.

Frequently asked questions

Do we need a 1600 number for EMI reminder calls?

If you are an RBI-regulated bank, NBFC or co-operative bank, yes. TRAI’s last phase date for these lenders was 1 March 2026. Ask your telecom provider to route AI calls through your 1600 numbers.

Should the AI agent say it is not a human?

Yes. It avoids confusion, keeps the call from feeling anonymous, and follows the FREE-AI committee’s advice.

Does the DPDP Act stop us from calling borrowers?

No. The Act permits processing for the purpose a person gave their data for, unless they say they do not consent. It asks you to protect the data, bind vendors by contract and erase data once the purpose is served, unless a law requires you to keep it.

Where to start

Start small, with a script your compliance team has signed off. AIMatric, Quipu’s AI division, builds AI voice calling and payment reminder agents that call in 100+ languages, including Kannada, Hindi, Tamil, Telugu, Marathi and English, send payment links on WhatsApp, capture promises to pay, hand over to your staff and send a daily collections report. Calls are consent-based and run within permitted calling hours.

Each engagement starts with a free 30-minute AI process audit, then a fixed-scope pilot, so you can test on your own borrowers before a wider rollout.