A Bank's Valuer Is Whoever Its Board Empanels. RBI Points the Qualification Back to 1957.

Chapter IX of the Reserve Bank of India (Commercial Banks — Credit Risk Management) Directions, 2025, RBI/DOR/2025-26/157, in force from 28 November 2025 and updated as on 1 July 2026, is the operative instruction on collateral valuation. It requires a Board approved policy, valuation "by professionally qualified independent valuers i.e. the valuer shall not have a direct or indirect interest," and a minimum of two independent valuation reports for properties valued at ₹50 crore or above.

Enforcement runs on a second instrument. Rule 8(5) of the Security Interest (Enforcement) Rules, 2002 requires the authorised officer to "obtain valuation of the property from an approved valuer" and, in consultation with the secured creditor, fix the reserve price. That is the valuation a borrower is most likely to litigate, and the one that decides what the debt is actually worth.

A third covers the loan itself rather than the security. Clause 53 of the Reserve Bank of India (Transfer of Loan Exposures) Directions, 2021 requires that where the credit exposure being transferred is ₹100 crore or more, the transferor obtain two external valuation reports. It prescribes no qualification for who writes them.

Between them these three cover origination, enforcement and disposal. Section 247 of the Companies Act, 2013 appears in none of them.

Paragraph 72 of the 2025 Directions is worth reading in full, because it changes verb twice:

• "A bank shall have a procedure for empanelment of professional valuers and maintain a register / record of 'approved list of valuers'."
• "A bank may prescribe a minimum qualification for empanelment of valuers."
• "While prescribing the qualification, the bank shall take into consideration the qualifications prescribed under Section 34AB (Rule 8A) of the Wealth Tax Act, 1957."

So the register is compulsory, the qualification standard is discretionary, and the reference point for a standard the bank need not set at all is a 1957 statute. There is no floor. A bank that prescribes nothing has complied with paragraph 72.

That anchor also moved this year. As set out in The 1957 Valuer Is Dead. The Income-tax Act Just Rebuilt It., the Income-tax Rules, 2026 rebuilt the Wealth-tax registration machinery under Section 514 of the Income-tax Act, 2025 with effect from 1 April 2026, carrying the Rule 8A categories over intact and continuing existing registrations subject to updating details by 30 September 2026. RBI's cross-reference still names the 1957 provision. The population behind it is now maintained under a different statute by a different regulator.

Paragraph 72(2) illustrates what different qualifications might attach to: "land and building, plant and machinery, agricultural land, etc." Set that list against the two registers it sits between.

Land and Building and Plant and Machinery are, name for name, two of the three asset classes in Annexure IV of the Companies (Registered Valuers and Valuation) Rules, 2017. Agricultural land is not a class there at all; it is a Rule 8A category. The illustration borrows from both lists, and omits from each the category that would cover financial collateral: Securities or Financial Assets on the 2017 side, securities and business assets on the 1957 side.

The omission is not academic. Pledged shares, loan exposures being transferred under Clause 53, and security receipts are all collateral that gets valued continuously and belongs to no class RBI thought to name. The problem is the mirror image of the one in A Land-Holding Company's Shares Are an SFA Job. The Land Underneath Isn't.: there, an SFA valuer needed a Land and Building valuer underneath. Here, a bank framework built around land and building has no route to the SFA valuer above it.

"Approved valuer" in Rule 8(5) is defined in Rule 2(d), and the widely used reproductions of that rule do not agree on what it says. One line of reproduction carries the definition as originally notified on 20 September 2002: "a valuer as approved by the Board of Directors or Board of Trustees of the secured creditor, as the case may be." Another carries it as substituted, reporting notification S.O. 1837(E) of 26 October 2007: "a person registered as a valuer under section 34AB of the Wealth-tax Act, 1957, and approved by the board of directors or board of trustees of the secured creditor."

This is stated rather than glossed: no official copy of the Rules could be reached here, and the India Code handle for the parent Act now resolves to a 404. The substitution is reported by one reproduction and absent from another that otherwise footnotes the 2007, 2016 and 2018 amendments carefully. Treat the current text as unresolved on the available evidence.

What both readings share is the answer to the question this archive keeps asking. Either the approved valuer is defined purely by the secured creditor's board, or by the same 1957 section paragraph 72 points to plus board approval. Neither reading reaches Section 247. That is one more entry for the count in Who Counts as a 'Valuer'? Six Statutes, Five Different Answers, and the one with the largest rupee value attached to it.

The Reserve Bank of India (Commercial Banks — Capital Charge for Credit Risk — Standardised Approach) Directions, 2026, RBI/DOR/2026-27/397 of 27 April 2026, are the first RBI instrument in this chain to name the Companies Act framework. Paragraph 16(1)(ii) ends: "Valuations shall be made as specified in the Reserve Bank of India (Commercial Banks — Credit Risk Management) Directions, 2025, taking into account inter alia the valuation standards notified by Central Government (viz. Companies (Registered Valuers and Valuation) Rules, 2017)."

There are no valuation standards notified by the Central Government. As traced in What Valuation Standard Actually Governs an SFA Registered Valuer?, Rule 18 obliges a registered valuer to follow standards notified by the Central Government and, until they are notified, internationally accepted standards or the standards adopted by their own Registered Valuers Organisation. A Rule 19 committee was constituted in 2018. Nothing has been notified since. The transitional limb has been the operative rule for the whole life of the regime.

So the single sentence connecting bank collateral valuation to the registered valuer framework points not at the register, nor at the qualification schedule, but at the one thing in the 2017 Rules that was never brought into existence. And the same paragraph closes the loop anyway: "The valuation done by a bank's empanelled independent valuer in terms of the Reserve Bank of India (Commercial Banks — Credit Risk Management) Directions, 2025 shall deem to comply."

The 2026 Directions take effect from 1 April 2027 and make property valuation a direct determinant of regulatory capital through loan-to-value risk weight buckets. The rule on which number goes into the ratio is asymmetric by design:

• Value is "reckoned at the value measured at origination unless the value of the property has been revised downwards (as per the bank's policy on periodic valuation)."
• Upward revision is permitted only after at least five years from the start of repayment or possession, whichever is later, and then only on a fresh valuation obtained for a new or additional loan against the same property.
• The bank is "expected to monitor the value of the collateral at least once in three years," with reappraisal by a qualified professional valuer where information indicates a material decline.
• The valuation "must be done independently from the bank's mortgage acquisition, loan processing and loan decision process," and must exclude expectations of price increases.

Read together, an origination valuation set too high is corrected downward on the next cycle; one set too low is locked in for five years and cannot be repaired by the market proving it wrong. The conservatism the Directions ask for is therefore not free. It has a capital cost that lands on the borrower, and the valuer setting the number at origination is the only person in the chain who can see it coming.

If you hold the Section 247 credential and want bank work, understand that empanelment is a commercial process run bank by bank under paragraph 72, not a consequence of registration. Ask which class you have been empanelled for and on what qualification basis, because the bank was never obliged to set one.

If you are drafting or reviewing a bank's valuation policy, paragraph 72(2) obliges consideration of Rule 8A, not adoption of it. Nothing stops a Board approved policy from requiring Section 247 registration in the relevant asset class where the collateral is securities or financial assets, and nothing currently requires it. That is a policy choice the framework leaves entirely open, and almost nobody has made it.

The gap here is not that banks appoint poor valuers; most large banks prescribe far more than RBI requires. It is that the statutory reference point for who may value a bank's collateral sits in a chapter of a 1957 Act whose register was relocated in 2026, while the register built for exactly this purpose in 2017 is named once in the entire chain — for a standard that does not exist.