India: Compliance

SEMM forms part of the Sanlam group of South Africa, whose ultimate controlling parent, Sanlam Limited, is entirely publicly held. SLIC provides life insurance in India and is held, inter alia, by Shriram Capital Private Limited (‘SCPL’) and SEMM.

On August 17, 2026, the Department of Telecommunications ("DoT") issued Circular no. 3/User Identification/2026 ("2026 Circular") to strengthen enforcement of the existing limits on mobile connections held by individual subscribers. Under the DoT instructions dated August 09, 2012, read with the reverification framework issued on December 07, 2021 ("2021 Instructions"), an individual may hold a maximum of nine mobile connections across all Telecom Service Providers ("TSPs") and Licensed Service Areas ("LSAs"), with a lower limit of six connections in Jammu & Kashmir, Assam and the North-East LSAs.

Most foreign companies spend months deciding how to enter India, i.e., whether to set up a subsidiary, form a joint venture with a local partner or open a branch. Far fewer spend the same effort on what happens once the entity exists. Yet it is usually after entry, when the business is running and the relationships are tested, that the gap between what an investor expected and what Indian law actually gives it becomes visible.

Loan recovery is an essential part of lending operations, but the methods adopted by financial institutions to recover outstanding dues have often raised concerns regarding borrower privacy, harassment and the misuse of recovery mechanisms. The Reserve Bank of India (RBI), through the Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Third Amendment Directions, 2026, dated 6 August 2026, has introduced a comprehensive framework governing the recovery of loan dues by non-banking financial companies (NBFCs).

The relationship between financial institutions and borrowers extends beyond the mere advancement and repayment of loans. It involves transparency in financial transactions, fair treatment of customers, responsible recovery practices and accountability throughout the lending process.

A foreign business can open a Liaison Office, Branch Office or Project Office in India, or it can set up an Indian subsidiary. Each option serves a different business purpose, and each carries its own corporate, foreign exchange and regulatory requirements.

The Reserve Bank of India has withdrawn seven legacy FEMA circulars as part of its ongoing rationalization initiative, affecting cross-border transactions, ECB frameworks, and foreign exchange compliance. This development underscores the importance of relying on current regulations rather than historical circulars when structuring international transactions.

In the same statewide drive, two of Mumbai’s best known eateries, a 122 year old Irani cafe near Marine Lines and a well-known upmarket Chinese restaurant, have had their food licenses suspended. Both cases pose the same legal questions about the speed of a regulator’s action, what it must prove and when a suspension must end.

The Digital Personal Data Protection Act, 2023 introduced a new privacy framework for India and established important roles for organisations handling digital personal data. Among the most important concepts are data fiduciaries and data processors. Understanding these roles is essential because the classification determines who decides why and how personal data is processed, who acts on another organisation's instructions and where compliance responsibility sits.