Legal & Insolvency

What is Inter-Creditor Agreement (ICA)?

An Inter-Creditor Agreement (ICA) under the RBI's 2019 framework is a binding agreement among lenders to a stressed borrower that lays down the resolution decision-making — majority threshold, dissenting lender treatment, payment waterfall and timelines for implementation.

MeaningAn Inter-Creditor Agreement (ICA) under the RBI's 2019 framework is a binding agreement among lenders to a stressed borrower that lays down the resolution decision-making — majority threshold, dissenting lender treatment, payment waterfall and timelines for implementation.
CategoryLegal & Insolvency
Related LawsRBI Prudential Framework, 2019
Who Uses ItBanks, ARCs, large borrowers
Why It MattersPre-condition for orderly out-of-court restructuring.
Detailed explanation

Inter-Creditor Agreement (ICA) explained in plain English

A practitioner's view written for borrowers and advisors — not a textbook definition.

An Inter-Creditor Agreement (ICA) under the RBI's 2019 framework is a binding agreement among lenders to a stressed borrower that lays down the resolution decision-making — majority threshold, dissenting lender treatment, payment waterfall and timelines for implementation.

In practice, Inter-Creditor Agreement (ICA) is used most often by banks, arcs, large borrowers. Each of them sees the term from a slightly different angle: borrowers care about protection and outcomes, lenders care about classification and recovery, regulators care about consistency and disclosure.

The legal anchor for Inter-Creditor Agreement (ICA) is RBI Prudential Framework, 2019. RBI master directions, the SARFAESI Act 2002, the RDB Act 1993 and the IBC 2016 commonly interplay, depending on the loan size, security and stage of stress.

Why does it matter? Pre-condition for orderly out-of-court restructuring. For a stressed borrower, getting this concept right early often saves several months of penal interest, legal cost and credit-score damage.

A real example: Eight lenders sign an ICA to implement a resolution plan for a stressed steel borrower. The mechanics may look complex, but the underlying logic — the bank wants closure, the borrower wants a fair outcome — is straightforward once the right framework is in place.

If you are facing a situation involving Inter-Creditor Agreement (ICA), the safest first step is a structured case review with a senior ex-banker who has handled comparable matters across banks and ARCs in India.

Where it is used

Where you'll encounter Inter-Creditor Agreement (ICA)

With borrowers and guarantors

Whenever a loan moves from "Standard" to "stressed", Inter-Creditor Agreement (ICA) is one of the words that starts appearing in notices, bank emails and lawyers' opinions.

Inside banks and NBFCs

Sanctioning committees, recovery teams and risk officers use Inter-Creditor Agreement (ICA) to classify accounts, decide provisioning and approve resolution paths.

Before DRT, NCLT and High Courts

Inter-Creditor Agreement (ICA) appears in pleadings, securitisation applications, OAs, Section 7/9 petitions and SARFAESI writs as part of the dispute record.

In ARC and investor transactions

When stressed loans are sold to ARCs or special-situations investors, Inter-Creditor Agreement (ICA) is used in term sheets, assignment agreements and due-diligence reports.

Real example

A practical illustration of Inter-Creditor Agreement (ICA)

Eight lenders sign an ICA to implement a resolution plan for a stressed steel borrower.
Note: The example is illustrative. Every case is fact-specific — actual outcomes depend on security cover, ageing of NPA, sanctioning level and the quality of documentation.
FAQs

Frequently asked questions about Inter-Creditor Agreement (ICA)

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Last reviewed by NPAExperts Advisory on 27 Jun 2026

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