IOanyT Innovations
Issue study: Banking Issue study · From the public record

Ten Months Without New Customers

A study from the public record of what the RBI named when it restricted a bank's new business over its IT, the options for finding out where an old system stands, what we would advise against, and the benchmark we would set.

By Updated 12 min read Figures checked against their sources on October 15, 2026

1. At a Glance

Issue study · From the public record. None of the organisations named here was an IOanyT client, and IOanyT had no part in the events described. Everything about them comes from the public record, reported without judgement on the institutions. IOanyT is not a compliance or audit firm, and nothing here is regulatory or legal advice.

Organisation typeAn Indian bank restricted by the RBI over its IT, set beside one Indian co-operative bank’s penalty and one UK fine
Size bandKotak Mahindra Bank: large. Andhra Pradesh Mahesh Co-operative Urban Bank: an urban co-operative bank. TSB Bank: large
RegionIndia; TSB Bank in the UK
The decision at stakeHow a firm on old systems learns where it stands, and what it puts in front of its board
The public outcomeKotak Mahindra Bank was barred from onboarding customers through its online and mobile channels and from issuing new credit cards for about ten months, from 24 April 2024 to 12 February 2025
Why it matters to a mid-size lenderThe remedy for IT failings can be a stop on new business, and regulatory action over IT has reached an urban co-operative bank too

2. The Business Problem, in the Buyer’s Words

“Our old system has been amber on the board report for years. Every team knows its own gaps: the server list is out of date, changes go in by hand, one vendor holds the knowledge. Nobody has put it together. If the inspectors asked tomorrow, we would spend a fortnight writing the answers, and I am not sure they would match what the system does.”

These words are imagined. They describe the position as the research shows it, not a real conversation.

The firm is not short of warnings. It is short of one written record of its own system, and a plan it could defend.

3. What We Found

Method. We went through the public record on regulatory action over IT in banking: the RBI’s direction on IT governance, its published enforcement releases, the UK regulators’ published findings on one failed migration, and one 2025 industry survey, from 2018 to 2025.

The restriction. On 24 April 2024 the RBI directed Kotak Mahindra Bank to “cease and desist, with immediate effect, from (i) onboarding of new customers through its online and mobile banking channels and (ii) issuing fresh credit cards”, while it kept serving its existing customers. The RBI lifted the restrictions on 12 February 2025.

WhatPublic record
Date of the order24 April 2024
What was barred”Onboarding of new customers through its online and mobile banking channels”; “issuing fresh credit cards”
Restrictions lifted12 February 2025
LengthAbout ten months
Areas named, in the RBI’s words”IT inventory management, patch and change management, user access management, vendor risk management, data security and data leak prevention strategy, business continuity and disaster recovery rigour and drill, etc.”
Also noted”Frequent and significant outages in the last two years”

It reaches co-operative banks. On 19 June 2023 the RBI announced a penalty of 65 lakh rupees on Andhra Pradesh Mahesh Co-operative Urban Bank, Hyderabad, by an order of 12 June 2023, for non-compliance with its cyber security framework directions. The RBI said its IT examination and an investigation of a cyber security incident showed the bank “had failed to put in place certain mandated controls which led to the cyber security incident”.

The rule. The RBI’s direction on IT governance, in force since 1 April 2024, says regulated entities “shall avoid using outdated and unsupported hardware or software”.

Moving badly is penalised too. TSB Bank in the UK migrated to a new IT platform in April 2018, and the migration failed. On 20 December 2022 its regulators fined it £48.65 million in total, finding that it had failed to manage the risks of its “IT outsourcing arrangements with its critical third-party supplier”.

How leaders see it. In one 2025 industry survey of 500 senior leaders at large mainframe-based enterprises, 94% said regulatory compliance strongly influences their modernisation decisions.

Our reading of why firms meet these areas unprepared. These are our reasoning from the cases above. None is a regulator’s finding.

  1. Each area belongs to a different team, and nobody holds all of them together.
  2. The areas are connected: a firm cannot patch what it has not listed, or oversee a supplier whose work it cannot read.
  3. The old system reaches the board as a budget request, not as a business risk, so it waits.
  4. When a finding comes, the response promises a date before anyone has read the system.

What this record does not show. The research read the RBI’s press releases, not its inspection reports or its letters to the banks, so it has the areas the RBI named and not the detail behind them. It saw no inspection questionnaire, finding or response letter, and does not know what deadlines the RBI sets. The RBI’s release does not say Andhra Pradesh Mahesh ran unsupported software. The survey covers large mainframe-based enterprises, not mid-size lenders. We found no named NBFC, broker, insurer or fintech restricted over an old system, and no figure for what a restriction cost in lost business.

4. The Options a Firm in This Position Had

OptionWhen it fitsWhat it risksOur view
Wait until someone asksThe systems are recent and documented, and past inspections found littleThe firm learns its position from someone else, on someone else’s timetableRight only where the systems are already in order
Fix the cited areas one by one, team by teamOne area is clearly weak and the rest are soundThe areas are connected; separate fixes do not add up to a planUseful for one urgent gap, not as the plan
Commission a compliance audit against the rulesThe firm needs an independent view of where it standsIt says what is wrong, not how to fix it inside the systemOften worth doing alongside; not work IOanyT does
Map the system, then build a staged plan with evidence at each stageThe system is old, layered and customisedAn assessment comes before any plan, and the stages take longer than one dateOur recommendation for the systems around the core

What we would have advised against: promising one completion date chosen before anyone had read the system, and replacing the whole system on one date to meet it. The first gives the board nothing to check until the date arrives. The second risks the kind of failure the TSB record shows.

5. Our Recommendation, and the Decision It Asks of the Board

For the systems a lender has built around its core (loan origination, collections, agent and branch portals, reporting): first write down what the system is, what it runs on and where each area the regulator has named stands. Then build a staged plan for the weak parts, one module at a time, with evidence at each stage, while the old system keeps running. What the firm tells its regulator is for the firm and its compliance advisers.

The decision it asks of the board: approve a fixed-price assessment before anyone else asks for the record. Then approve each stage on its own evidence, with the freedom to pause after any accepted module. The board replaces one amber line with a position on each area and a plan it can check.

6. Benchmark: Where You Are Now, and Where You Should Be

These are targets, not results. In an engagement the starting points are replaced by the firm’s own figures, taken in the first review.

MeasureTypical starting pointWhere it should beHow it is checked
An IT inventorySeveral lists that do not agreeOne complete record of what runs and what depends on itThe record is compared with the servers, databases and code
Each area in the RBI’s 24 April 2024 releaseKnown to each team, never put togetherWhat the system record shows on each area, in one placeThe risk register
A dated, staged planOne completion date, or noneStages of one module each, dated by the firmThe staged plan with a fixed quote
Evidence for each stageNothing to show until the endA record of what moved and how it was checked, for every accepted moduleThe traceability matrix
Board reportingOne amber line, carried forwardThe position on each area and progress against the planBoard papers, at every review

The areas are the ones the RBI listed in one bank’s case. Using them as headings is our choice, not a statement of what the RBI expects any firm to show.

7. How IOanyT Would Work

  1. We listen: a free Reliability Review. A first conversation about the system, what past inspections have asked, and what the growth plan depends on. You leave with a short written note of what we found.
  2. We research. We research your sector, the regulator’s position and what the public record says about firms in your situation. This study is an example of that work.
  3. We read the system and propose: the Legacy System Specification Assessment. It produces a map of the system as it stands, a written specification of what it does, a risk register, a cost comparison between keeping and replacing the system, and a staged plan with a fixed quote. AI does a first pass, our senior engineers review it and trace it to the code, and your own experts confirm it. Code access is read-only and logged, never used for training, and deleted within 30 days of the evaluation ending unless we engage.
  4. If you approve, we build. We replace a system one module at a time while the old one keeps running. We never do a single cutover. A traceability matrix links every old function to its replacement. The work is billed by milestone, each milestone tied to a module you accept, and you can pause after any accepted module.
  5. We review against the benchmark. Before work starts we set the benchmark. After each module we show you where each measure stands, and the filled-in benchmark is yours at the end.

The Review is free. Every paid step is fixed price, agreed at scoping. Stop after any step. The findings are yours. The assessment fee is credited in full against the first build stage if it starts within 90 days of the report.

A firm examined on vendor risk will check its suppliers, IOanyT included. IOanyT is certified to ISO 9001, ISO/IEC 27001 and ISO/IEC 42001.

8. What the Client Would Own

  • The map and the specification: what the system is and what it does, in writing and portable to any supplier.
  • The risk register: the weak parts, ranked, before any price is set.
  • The staged plan: each stage, in order, with a fixed quote, for the firm to date and to take to its board.
  • The traceability matrix: for each replaced module, every old function linked to its replacement, with how it was checked.
  • The code: the new modules are the client’s.
  • The filled-in benchmark: each measure, where it started and where it stands.

9. What This Approach Does Not Cover

  • IOanyT is not a compliance or audit firm. It offers no RBI or DPDP compliance service and no legal advice, and does not say what a regulator requires.
  • IOanyT does not write a firm’s response to a regulator. What the firm tells its regulator is its own decision.
  • IOanyT cannot promise that a regulator will accept a plan, lift a restriction or withhold a penalty.
  • IOanyT does not secure, patch or maintain the old system in the meantime, and does not supply security controls such as access management or firewalls. The client’s current team or vendor does that.
  • IOanyT does not work on mainframes or core banking products.
  • This study does not say IOanyT would have prevented the events described, or that IOanyT has done this work for a bank.

About this study: IOanyT did not work on this case. It is drawn from published findings, cited below.

10. Sources

SourceUsed for
RBI press release 2024-2025/172, 24 April 2024Kotak Mahindra Bank: the restriction and the areas named
RBI press release 2024-2025/2139, 12 February 2025Lifting of the restrictions
RBI press release 2023-2024/435, 19 June 2023Andhra Pradesh Mahesh Co-operative Urban Bank: the penalty and the RBI’s finding
RBI Master DirectionThe rule on unsupported hardware and software
Bank of England, 20 December 2022TSB Bank fine and finding
News report of a vendor’s survey, 9 September 2025The survey figure

IOanyT is a consultancy with its own engineering team: we study the problem, recommend, and prove it by building only what you approve. We give a firm the facts about its own system and a staged plan; what it does with them is its own decision.

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