The app may market, score and service the loan. The regulated bank or NBFC behind it remains responsible for the credit relationship and borrower protection.
Quick View
RBI Directions, 2025
KFS and APR
Borrower to lender
Need-based consent
What Matters Now
The Reserve Bank of India (Digital Lending) Directions, 2025 consolidate requirements for regulated entities and their lending service providers. They apply to digital lending by banks, specified co-operative banks, NBFCs including housing finance companies and all-India financial institutions.
Borrowers should see the regulated entity’s name, loan amount, tenor, APR, monthly repayment obligation, penal charges and a link to the KFS. Digitally signed loan documents should flow to the registered email or SMS channel.
The directions also restrict pass-through fund flows and unnecessary mobile-data access. The regulated entity remains responsible even when an LSP operates the interface.
How It Works
| Stage | What happens | Control |
|---|---|---|
| Offer | The app presents one or more lender offers. | Compare lender, APR, instalment and charges. |
| Contract | The borrower receives KFS and signed documents. | Save them before disbursal. |
| Money | Disbursal and repayment normally flow directly between borrower and lender. | Avoid personal or pool accounts. |
| Data | Collection must be need-based with explicit consent and audit trail. | Reject access to contacts and call logs. |
Decision Framework
Start with the exact decision being made. A payment choice, credit facility, investment, policy, remittance or compliance step should not be judged only by convenience or headline return. For Digital Lending: Finding the Real Lender, the four useful lenses are main rule: RBI Directions, 2025; disclosure: KFS and APR; fund flow: Borrower to lender; data rule: Need-based consent.
Next, identify the downside before considering the expected benefit. Ask how much money can be lost or delayed, which obligation becomes fixed, who controls the data or asset, what happens when the provider fails, and which official complaint or appeal route remains available. This converts a marketing claim into a testable decision.
Finally, define the review trigger. A rule change, missed payment, benefit revision, sharp market move, data incident, unresolved reconciliation or change in personal cash flow should reopen the decision. Evidence should be collected when the transaction occurs, not reconstructed after a dispute.
- Offer: Compare lender, APR, instalment and charges.
- Contract: Save them before disbursal.
- Money: Avoid personal or pool accounts.
- Data: Reject access to contacts and call logs.
Who Bears the Risk
| Participant | Primary responsibility | Failure to avoid |
|---|---|---|
| User or customer | Read the terms, authorise deliberately, preserve records and act within personal cash-flow or risk limits. | The lender’s name is hidden. |
| Provider or intermediary | Make accurate disclosures, operate the agreed process, protect data or assets and maintain a usable grievance route. | The app requests contacts or call logs. |
| Adviser or finance team | Apply the current rule to the actual facts, separate assumptions from evidence and explain material downside clearly. | Repayment goes to a personal account. |
Regulation can allocate duties, but it cannot remove commercial or market risk. The safest operating approach is to know which participant owns each step and to escalate an exception before money, data or legal rights become difficult to recover.
Practical Example
Action Checklist
- Identify the regulated lender.
- Read the KFS and APR.
- Check direct disbursal and repayment details.
- Review each data permission.
- Use the cooling-off option when needed.
- Escalate unresolved complaints after first approaching the lender.
Evidence to Keep
- KFS and sanction letter.
- Loan agreement and account statement.
- Consent and permission log.
- Bank fund-flow records.
- Complaint and recovery-agent details.
Warning Signs
- The lender’s name is hidden.
- The app requests contacts or call logs.
- Repayment goes to a personal account.
- Charges appear outside the KFS.
- Recovery agents contact before formal communication.
Common Questions
Who is responsible when an LSP runs the app?
The regulated entity remains responsible for compliance and the acts of its service provider within the arrangement.
What is APR?
It is an annualised measure intended to reflect the cost of credit under the applicable KFS framework.
Can the app raise the limit automatically?
The directions state that credit limits should not automatically increase without an explicit borrower request that is evaluated and recorded.
How long is the cooling-off period?
The lender’s policy sets it, but the RBI directions require at least one day.
Official Sources
Rules, rates, product terms and portal processes can change. Use the latest official text and transaction-specific facts before acting.