India is moving from a backward-looking incurred-loss model to a forward-looking, lifetime-loss framework for credit provisioning, in line with IFRS 9. The Reserve Bank of India's Final Circular of April 2026 sets the timeline: an October 2026 parallel run, an April 2027 go-live, and supervisory reviews after that. The circular is specific about what banks must actually build: macroeconomic variables embedded structurally into the models rather than layered on afterward, staging criteria validated independently, and every ECL figure in the financial statements traceable back to a system-generated output. These aren't aspirational goals; they're what examiners will check from day one. Meeting the deadline is not the same as being ready for what comes after it.
Drawing on global IFRS 9 experience and BCG's work with financial institutions, this report sets out eight questions spanning governance, data, models, technology, and capital planning that boards and management teams must answer before go-live. Answering them well depends on four capabilities working together: data governance, model architecture, governance and controls, and technology and operations. Indian banks carry some extra weight here. PSU mergers have left several banks running merged portfolios across stitched-together core banking platforms, each with its own legacy customer identifiers, and collateral records for priority-sector and agricultural loans are still tracked on paper in many rural branches.
Banks that treat ECL as a compliance exercise tend to finish on time, then spend the next two years explaining provision swings and rebuilding models under pressure. The ones that get it right treat ECL as a structural change to underwriting, pricing, capital allocation, and investor communication. Closing the gap between compliance and credibility costs more after go-live than before it.
