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Walk into the locker room of many bank branches and you’ll still find the same things: a thick register, a key cabinet and a spreadsheet someone updates on Friday afternoons. For years, that was enough. Lockers were a quiet service that rarely made it onto anyone’s dashboard.

RBI’s locker rules changed that. They apply to every safe deposit locker and safe custody facility, old and new, from January 1, 2022, and banks must have a Board-approved locker policy and SOPs (para 216). For commercial banks, the rules now sit in Section C of the Responsible Business Conduct Directions, 2025. The paragraph numbers below refer to that document, as updated on October 1, 2026. Other types of bank should check the Directions that apply to them.

Here’s what the rules ask you to keep track of, and where a paper register lets you down.

1. The waitlist has to live in a system

Banks must keep a branch-wise list of vacant lockers and a waitlist in the core banking system, or another computerised system that meets RBI’s cyber security framework. Every application must be acknowledged. If no locker is free, the customer gets a waitlist number.

Where registers fall short: a handwritten waitlist can’t show that lockers were allotted fairly, and it can’t tell a customer where they stand in the queue.

2. Every hirer needs a valid agreement

Banks need a locker agreement approved by their Board, and they can use the model agreement drawn up by the Indian Banks’ Association (para 222).

Where registers fall short: working out which hirers have signed the latest version, and finding the signed copy, turns into a hunt every time an auditor asks.

3. There are limits on rent security

When a locker is allotted, a bank can ask for a term deposit large enough to cover three years’ rent plus the cost of breaking the locker open if it ever comes to that. It can’t ask existing locker holders, or customers with a satisfactory operative account, for this deposit. Tying lockers to deposits beyond that counts as a restrictive practice (para 226). And if a customer surrenders a locker after paying rent in advance, the unused portion has to be refunded (para 227).

Where registers fall short: due dates, deposits, refunds and penalties are easy to lose track of when a branch has hundreds of lockers.

4. Every visit is logged, and the customer is told

Banks must keep a digital record of access to the locker room or vault, with times. Under its own security policy, a bank may also cover the strong room entrance, exit and common areas with CCTV, keeping the footage for at least 180 days, or longer if there’s a complaint or police investigation (para 230). After every locker visit, the customer must get an email and an SMS before the end of the day, giving the date and time of access and how to raise a complaint (para 237).

Where registers fall short: a signature in a book isn’t a digital time log, and paper can’t send anyone an SMS.

5. Locks change when a locker is surrendered

Locks must be swapped every time a locker is surrendered. Keys to empty lockers stay in sealed envelopes, and duplicate master keys are kept at another branch (para 238).

Where registers fall short: keeping track of keys across branches is hard without a record tied to each locker.

6. Dormant lockers follow a set process

If a locker hasn’t been operated for seven years and the hirer can’t be found, the bank may hand the contents to the nominees or legal heirs, or dispose of them transparently, following the prescribed procedure. This applies even if the rent is still being paid (para 254).

Where registers fall short: spotting seven years of inactivity across a whole branch network needs data that no register will give you at a glance.

7. Liability can reach 100 times the annual rent

Banks aren’t liable for losses caused by natural disasters or by the customer’s own fault. But if the contents are lost to fire, theft, burglary, dacoity, robbery or building collapse because of the bank’s own failings or negligence, or through fraud by bank staff, the bank owes an amount equal to 100 times the current annual rent (para 258).

Where registers fall short: when there’s a dispute, the bank has to show what it did. That proof sits in access logs, alerts, CCTV and audit trails. A register won’t carry it.

A quick self-check for your locker operations

  • Is your waitlist in the core banking system or another compliant system, with a number given to every applicant?
  • Could you list, today, which hirers have signed your current agreement?
  • Are rent dues, deposits and refunds worked out automatically?
  • Does every locker visit create a time log and a same-day SMS and email?
  • Can you pull up a list of lockers that have been untouched for seven years?
  • Could you produce the full history of any locker within an hour?

How SAFE takes lockers off paper

We built SAFE, our Locker Management System, to run the whole locker lifecycle in one place, connected to the bank’s core banking system:

  • Setup and onboarding. Branches, lockers, racks and keys are set up as masters. Customer details, KYC and photos come straight from core banking.
  • Waitlist and allotment. When lockers are full, customers join a waiting list that allocates automatically. Every allotment goes through maker-checker approval.
  • Rent through core banking. Rent is debited from the customer’s account and posted to the general ledger, and a receipt is issued. Rent demands are raised automatically.
  • Digital agreements. Locker agreements and nominee forms are generated as PDFs, Aadhaar e-signed and filed in the document management system.
  • Biometric access. A fingerprint scan logs every entry to and exit from the locker room, with a timestamp and an SMS alert.
  • Workflows built for lockers. Key loss, blocking, complaints, break-open for court or death cases, claims settlement and a found-items register, each with its own approval flow.
  • Account controls. Lien marking and deceased-customer checks through core banking.
  • Rules without code. Rent and discount slabs, charges, GST split, reminder tiers, penalties and rent periods of one to four years are set up for each bank.
  • A view from the top. Dashboards from all-India level down to zone, region and branch, with standard reports and bulk SMS and email notices.

Frequently asked questions

Do RBI’s locker rules apply to old lockers too? Yes. Since January 1, 2022, they’ve applied to both new and existing lockers and safe custody facilities.

How much is a bank liable for if locker contents are lost? An amount equal to 100 times the current annual locker rent, if the loss comes from fire, theft, burglary, dacoity, robbery or building collapse caused by the bank’s negligence, or from fraud by its staff. Banks aren’t liable for natural disasters or losses caused by the customer.

Can a bank make me open a fixed deposit to get a locker? Only a term deposit covering three years’ rent and break-open charges, and not if you’re an existing locker holder or have a satisfactory operative account.

Will my bank tell me every time my locker is opened? Yes. You should get an email and an SMS before the end of the day, with the date and time of access.

How long do banks keep locker-room CCTV footage? Where a bank uses CCTV under its security policy, footage must be kept for at least 180 days, and until any related complaint or investigation is closed.

Ready to retire the register?

See a locker go from waitlist to allotment, rent debit, biometric access and surrender, with every step on record. Book a SAFE demo.

This article is for general information and isn’t legal or regulatory advice. It reflects RBI Directions as updated on October 1, 2026. Requirements vary by type of bank and can change. Check the latest Directions that apply to you and talk to your compliance team.