When the Maker Stops Fixing the Software
A study of unsupported software in financial services from the public record: the RBI's position, a shared core retired by its vendor, the options a lender has, what we would advise against, and the benchmark we would set.
1. At a Glance
Issue study: a public case, not an IOanyT client. 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.
| Organisation type | A group of more than 40 credit unions sharing one core system, set beside the RBI’s position on unsupported software and one Indian bank it restricted |
| Size band | The credit union group: 150 branches and 300,000 members. The Indian bank: large |
| Region | The credit union group: not stated in the source. The regulator and the bank: India |
| The decision at stake | What to do when the maker of a system sets the date its support ends |
| The public outcome | The shared core was retired on its vendor’s date, and the group rebuilt more than 200 screens and more than 500 interfaces. In India, the regulator now tells regulated entities to avoid unsupported software, and cited IT inventory when it restricted one bank for about ten months |
| Why it matters to a mid-size lender | Most lenders run something past its maker’s end date. The question is whether they leave on their own plan or on someone else’s |
2. The Business Problem, in the Buyer’s Words
“Every year the same letter comes from the vendor, and every year we sign for extended support because it is smaller than the replacement quote. Then the auditor asks for a list of everything we run that is out of support, and three teams send three spreadsheets that do not agree. We know we have to leave. We just never have a plan we can put in front of the board.”
These words are imagined. They describe the decision as the research shows it, not a real conversation.
The firm is caught between a date it does not control and a list it does not have. Staying looks cheaper every year, and leaving never gets a plan.
3. What We Found
Method. We went through the public record on unsupported software in financial services: the RBI’s direction on IT governance, its enforcement actions as reported in the press, a vendor’s published case study, makers’ published support dates and the US government’s list of flaws known to be exploited, from 2022 to 2026.
When the vendor sets the date. A group of more than 40 credit unions, with 150 branches and 300,000 members, shared one core system. It was “heavily customized”. Its vendor scheduled it to sunset in August 2024. The institutions did not choose the date and could not move it.
| What | Figure |
|---|---|
| Institutions sharing the system | More than 40 credit unions |
| Their size | 150 branches, 300,000 members |
| The system | ”Heavily customized”, scheduled to sunset in August 2024 |
| What the replacement rebuilt | More than 200 screens and more than 500 interfaces to other systems |
What the regulator says. The RBI’s direction, in force since 1 April 2024, says regulated entities “shall avoid using outdated and unsupported hardware or software”. In April 2024 the RBI barred Kotak Mahindra Bank from taking new customers through its online and mobile channels and from issuing new credit cards. Among the areas it cited were IT inventory management and patch and change management. The restrictions lasted about ten months.
Dates are published, and extensions end too. Standard support for IBM i version 7.4 ended on 30 September 2026, with a paid extension to 30 September 2029. As of 11 October 2026, the US government’s list of flaws known to be exploited held 9 entries for Apache Struts and 13 for WebLogic Server, two building blocks under many business applications.
What open gaps cost: a background case. In June 2023 the RBI imposed a penalty of 65 lakh rupees on Andhra Pradesh Mahesh Co-operative Urban Bank, a mid-size Indian bank, finding that “the bank had failed to put in place certain mandated controls which led to the cyber security incident.”
Our reading of why firms stay past the date. These four are our reasoning from the cases above. None is a regulator’s finding.
- Nobody has the list: there is no single record of what runs, the support date of each item and what depends on it.
- Everything depends on everything: the application needs the old framework, which needs the old server, so moving one means moving several.
- Nobody has a written record of what the system does, so leaving feels riskier than staying.
- Staying looks cheaper this year, because one renewal is set against the whole cost of leaving.
What this record does not show. The credit union source is a vendor’s own case study, and it does not say where the institutions are or how the replacement went. The Kotak record gives only the headings the RBI cited, not what the bank ran. The RBI’s finding on the co-operative bank is about missing security controls and does not say the bank ran unsupported software. The list of exploited flaws does not show that any particular firm is exposed. We found no public case of a mid-size NBFC, broker or insurer with this problem, and no published figure for what extended support costs.
4. The Options a Firm in This Position Had
| Option | When it fits | What it risks | Our view |
|---|---|---|---|
| Renew extended support each year | A firm date to leave already exists | The system stands still while renewals add up, and the option ends on the maker’s date | Right only as a bridge with an end date |
| Upgrade in place to the maker’s newer version | The application runs on the new version with small changes | Old applications need the old layers below them; the upgrade becomes a rebuild | Worth checking first; often not possible |
| Replace the whole system on one date | The system is small and well documented | One date carries all the risk, and the list of what runs is still missing | We would advise against this for an old, layered, customised system |
| Write down what runs, then leave in stages, most exposed parts first | The system was built around the business and customised for years | Several stages, and two systems side by side for a time | Our recommendation for the systems around the core |
What we would have advised against: for a firm in this position, answering an audit finding with “upgrade planned” and no list behind it, and renewing extended support year after year with no date to leave.
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 runs, who still fixes it and what depends on it, then leave in stages, moving the most exposed parts first, while the old system keeps running. Use extended support, where it is offered, as a bridge with an end date.
The decision it asks of the board: approve a fixed-price assessment now, separately from the next renewal. Then approve each stage on its own evidence, with the freedom to pause after any accepted module. The board stops renewing the same position each year and starts approving a plan with dates the firm has set.
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.
| Measure | Typical starting point | Where it should be | How it is checked |
|---|---|---|---|
| A record of what runs | Several spreadsheets that do not agree | One record of every application in scope and every layer under it | The record is compared with the servers, databases and code |
| Items past their maker’s support date | Not counted, or counted only when asked | Each one listed, with what depends on it | The risk register |
| A plan against each item | ”Upgrade planned” | A stage, in order, against each item | The staged plan |
| Whose date the plan follows | The maker’s | The firm’s own, set before the maker’s | The staged plan |
| Accepted risks with an end date | None | Every one tied to the stage that removes it | The risk register beside the plan |
| The count over time | Rebuilt at each audit | Falling with each stage | Reported at every review |
7. How IOanyT Would Work
- We listen: a free Reliability Review. A first conversation about the system, the maker’s dates, and what the auditor or regulator has asked. You leave with a short written note of what we found.
- 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.
- 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.
- If you approve, we build. We replace a system one module at a time while the old one keeps running, onto technology that is still supported. 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.
- 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.
8. What the Client Would Own
- The map and the specification: what runs, and what the system does, in writing and portable to any supplier.
- The risk register: the items past support and what depends on them, listed before any price is set.
- The traceability matrix: every old function linked to its replacement, with how it was checked.
- The code: the new modules are the client’s. No runtime or platform fee.
- The filled-in benchmark: each measure, where it started and where it stands.
9. What This Approach Does Not Cover
- IOanyT does not patch or upgrade old software in place, and does not sell extended support.
- IOanyT does not keep the old system protected while it waits to move, and does not supply security controls. The client’s current team or vendor does that.
- IOanyT does not implement packaged core banking products, and does not work on mainframe platforms.
- Taking a plan to the regulator is the firm’s own job. Our assessment gives it the evidence to do so.
- This study does not say IOanyT would have prevented the events described, or that IOanyT has done this work for a bank.
10. Sources
| Source | Used for |
|---|---|
| A vendor’s case study | The credit union group |
| RBI Master Direction | The rule on unsupported software |
| TechCrunch, 24 April 2024; News On AIR; RBI press release, 24 April 2024; RBI press release, 12 February 2025 | Kotak Mahindra Bank restrictions, the areas cited and their end |
| endoflife.date, IBM i | IBM i 7.4 support dates |
| CISA catalogue | Exploited flaws in Apache Struts and WebLogic Server |
| RBI press release, 19 June 2023 | The RBI’s penalty on Andhra Pradesh Mahesh Co-operative Urban Bank and its finding |
IOanyT is a consultancy with its own engineering team: we study the problem, recommend, and prove it by building only what you approve. The maker sets its date; the plan for leaving can be yours.
Read the research notes on this issue
Unsupported software and hardware
Research note 1
Unsupported Software Is Now a Board Matter. Most Firms Cannot Say Where It Is.
Regulators now treat software past its end of support as a board matter, yet most lenders cannot say where it runs. What we found, the options, our benchmark.
Research note 2
Your Software's Maker Has Set the Date. The Plan Can Still Be Yours.
Extended support buys time and nothing else. What staying on software past its maker's date costs a lender, four ways to answer the letter, and our benchmark.
Research note 3
"Accepted Again" Is Not a Plan. A Shrinking Register Is.
Past end of support, a new flaw has no fix and is accepted again. The benchmark we would set to close those gaps, and the order the exposed parts move.