From October 1, 2026, the procedure for accounting for the risk of unfair conduct when assessing banks' activities will change. If a low rating persists for two quarters, a credit institution may face an increased contribution to the deposit insurance system – its size will be 400% of the base rate. This includes cases of incomplete disclosure of terms and risks of financial products, imposing services, and selling complex investment instruments without the required client testing.
This refers to cases where clients are not fully informed about contract terms and associated risks, are pressured into financial services, or are sold complex investment products in violation of mandatory testing. The Bank of Russia specifically points to cases of such transactions being concluded without mandatory testing or in violation of the established procedure. However, the assessment will not be automatic: the Central Bank will consider the severity of the violation and the bank's measures to rectify it.
If a bank receives a low rating for indicators related to the risk of unfair conduct and maintains it for two consecutive quarters, this may lead to increased contributions to the Deposit Insurance Fund. The additional rate is 300% of the base rate. Together with the base rate, this amounts to 400%, meaning the bank transfers four times the usual amount.
It is clarified that this will not affect clients. The additional burden arises for the credit institution itself through mandatory contributions to the deposit insurance system. The Central Bank expects this to create an additional economic incentive for banks to monitor how employees sell financial products, explain their terms, and disclose associated risks.
However, market participants fear that not only systematic sales problems may fall under the new mechanism. The Association of Banks of Russia points to the risk of technical violations – for example, a bank may violate the established client response deadline several times due to an information system failure. The Central Bank emphasizes that the assessment will not be automatic: the regulator will consider the severity of the violation and the bank's measures to rectify it.