Rules / regulations / directions
Reserve Bank of India (Digital Lending) Directions, 2025
Reviewed by CA Nikhil Gupta · Last reviewed 18 September 2026
Reserve Bank of India; RBI/2025-26/36 dated 8 May 2025. The instrument consolidates digital-lending requirements across regulated entities and, for NBFCs, relies in part on Sections 45JA, 45L and 45M.
Scope, legal role and applicability
Consolidated digital-lending conduct framework for regulated entities. For NBFCs, the Directions expressly draw authority from Sections 45JA, 45L and 45M, among other statutes.
Operative requirements
- The regulated entity remains responsible for regulatory compliance even when an LSP or DLA performs customer-facing or operational functions.
- Give the borrower the required Key Fact Statement and APR-based disclosure before execution; retain the digitally signed loan documents and disclosure trail.
- Route disbursal and repayment through the permitted fund-flow architecture. A convenience arrangement with an LSP does not override the direct-flow rules or stated exceptions.
- Build and evidence the cooling-off/look-up facility and grievance-redress route in the digital journey, including escalation to the regulated entity.
- Collect and store customer data only to the extent permitted, with need-based access and explicit consent where required; audit app permissions and LSP data practices.
- Report/maintain DLA details as required and ensure the public-facing association of the DLA with the regulated entity is accurate.
- For DLG, test eligible provider/form, portfolio cap, invocation timeline, disclosure and excluded exposures. RBI’s regulatory handbook records a 5% portfolio cap and an invocation period within 120 days.
Records, forms and annexures
Preserve KFS/APR output, sanction/loan agreement, borrower consents, app-permission audit, disbursal/repayment ledger, cooling-off exercise, grievance log, LSP contract, DLA-reporting submission and DLG portfolio register/disclosures.
Practical advisory example
Facts and issue. An NBFC uses an LSP that collects an onboarding fee directly from borrowers and routes repayments through the LSP account. The review should test borrower-charge treatment and fund flow against the Directions, then trace the KFS, consent, grievance and DLA-reporting evidence.
Working method. Classify the entity/product, identify the exact paragraph in force on the event date, test exceptions and transitional provisions, then retain the evidence listed above. Do not rely on the title of the Direction or an old Master Direction version.
RBI Act / cross-law linkage
Official source and version control
Questions and answers
What is the main purpose of Reserve Bank of India (Digital Lending) Directions, 2025?
Reserve Bank of India; RBI/2025-26/36 dated 8 May 2025. The instrument consolidates digital-lending requirements across regulated entities and, for NBFCs, relies in part on Sections 45JA, 45L and 45M.
Which part of Reserve Bank of India (Digital Lending) Directions, 2025 should be checked first?
Start with regulated entity - lending service provider - digital lending app accountability and then apply this requirement: The regulated entity remains responsible for compliance even where an LSP/DLA performs customer-facing functions.
What record should be retained?
Map annexures, DLA reporting and disclosure formats from the official Direction; retain screenshots/versioned policy artefacts for digital-journey testing.
Does this page treat the RBI Act as the only enabling law?
No. Current consolidated digital-lending requirements; RBI/2025-26/36 dated 8 May 2025. For NBFCs it expressly relies on sections 45JA, 45L and 45M among other statutes.