Digital lending can look like a technology workflow, but the financial and conduct responsibility remains with the regulated entity. RBI’s consolidated Directions make that accountability visible across contracts, product screens, data, recovery and reporting.
What changed in the operating picture
The Directions consolidate earlier instructions and add requirements for loan-product aggregation involving multiple regulated entities and for reporting digital lending apps to RBI.
They cover due diligence and periodic review of lending service providers, borrower creditworthiness, disclosures, disbursal and repayment flows, cooling-off periods, grievance redressal, data collection and storage, app reporting and default-loss guarantee arrangements.
Where finance leadership adds value
Compliance is not only a legal checklist. Product economics, partner incentives, complaint trends, loss assumptions and operational controls should be visible in management reporting.
A regulated entity remains responsible for the acts and omissions of its service providers. That makes vendor governance, portfolio monitoring and exception reporting board-level financial-control issues.
What leaders should do now
- Create a complete register of lending service providers, apps, contracts, product flows and accountable owners.
- Test customer screens for comparable, unbiased offer presentation and complete Key Facts Statement links.
- Reconcile app reporting, complaints, recovery-agent changes and data-consent controls to board reporting.
- Review default-loss guarantee economics, caps, recognition and portfolio monitoring with finance and risk teams.
CFO PERSPECTIVEThe strongest compliance framework connects customer conduct with unit economics and control evidence. Dashboards should show not only growth and yield, but also complaints, exceptions, partner concentration, loss performance and remediation ownership.
CA Jigarkumar Shah
Read the original material
Reserve Bank of India (Digital Lending) Directions, 2025 — RBI/2025-26/36
Important: This article is general information and a business perspective based on the cited source. It is not legal, tax, accounting or investment advice. The law and official guidance may change; obtain advice for your facts before acting.