FinTech & Digital Lending Compliance

RBI Digital Lending Guidelines compliance for lending apps and FinTech platforms — KFS format, Loan Service Provider agreements, data privacy, and Fair Practices Code.

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Overview

RBI issued the Digital Lending Guidelines 2022 (revised Master Directions) to regulate the rapidly growing digital lending ecosystem. All banks, NBFCs, and Regulated Entities (REs) engaging in digital lending — including those partnering with Lending Service Providers (LSPs) and apps — must comply with these guidelines. Key requirements include: Key Fact Statement (KFS) disclosure to all borrowers before loan sanction; all credit must flow directly to the borrower's bank account; all repayments must flow directly to the RE without pass-through via LSP; data collection limited to purpose-specific consent; Annual Percentage Rate (APR) disclosure; and grievance redressal mechanism.

FinTech companies acting as LSPs (Buy Now Pay Later platforms, lending apps, credit marketplaces) must be registered with a Regulated Entity, comply with data privacy requirements, and not hold customer funds. MFiling audits your current lending tech stack, identifies compliance gaps, and implements all required policy, process, and technology changes for RBI Digital Lending Guidelines compliance.

MFiling professional charges: from Rs.19,999 for compliance gap assessment and policy implementation.

Key Benefits

Avoid RBI Enforcement Action
Non-compliant digital lenders face show-cause notices, app store takedowns, and CoR cancellation.
KFS and APR Disclosure Framework
Compliant Key Fact Statement and APR calculation framework protects against misselling allegations.
Compliant LSP Agreement Structure
Properly structured Lending Service Provider agreements protect both the RE and the fintech LSP.
Data Privacy and DPDP Compliance
Digital lending data collection policies aligned with both RBI guidelines and DPDP Act 2023.
Borrower Grievance Redressal System
RBI-compliant grievance mechanism with 30-day resolution timelines as mandated.

Documents Required

Current Loan Agreement / Sanction Letter Templates
Mobile App and Website Privacy Policy
Lending Service Provider (LSP) Agreement with RE Partner
Current KYC / Onboarding Process Documentation
Technology Architecture showing Fund Flow

How it Works

Digital Lending Compliance Audit (Week 1–2)

Review current loan documentation, app features, data collection, and fund flow against RBI guidelines.

Gap Analysis Report (Week 2)

Identify all non-compliant elements — KFS missing, improper fund flow, excess data collection, no APR disclosure.

Draft Compliant KFS Template (Week 2–3)

Prepare KFS format with all mandatory disclosures — loan amount, APR, processing fee, repayment schedule.

Revise Loan Agreements (Week 3–4)

Update loan agreements to include all RBI-mandated disclosures and borrower rights.

LSP Agreement Restructuring (Week 3–5)

Restructure technology and commercial agreements between fintech LSP and RE partner for compliance.

Grievance Mechanism Implementation (Week 4–6)

Set up nodal officer, grievance portal, and RBI Ombudsman escalation pathway.

Frequently Asked Questions

Can a FinTech company lend money without an NBFC licence?
A FinTech company without an RBI licence cannot lend its own money. However, it can act as a Lending Service Provider (LSP) — acting as a technology partner or marketplace for a licensed bank or NBFC that actually disburses the loans. The LSP model requires formal written agreement with the Regulated Entity (RE), compliance with RBI Digital Lending Guidelines, and ensures no customer funds flow through the LSP.
What is a Key Fact Statement (KFS) under RBI Digital Lending Guidelines?
A KFS is a standardised document provided to every borrower before loan acceptance, disclosing: loan amount, Annual Percentage Rate (APR) including all fees, repayment schedule, total interest payable, prepayment terms, and grievance officer contact. Borrowers must affirmatively accept the KFS before disbursement. Non-compliance attracts RBI enforcement action. MFiling prepares compliant KFS templates for lending app clients.
Service Price
₹19,999
Starting price · GST extra
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Avoid RBI Enforcement Action
Non-compliant digital lenders face show-cause notices, app store takedowns, and CoR cancellation.
KFS and APR Disclosure Framework
Compliant Key Fact Statement and APR calculation framework protects against misselling allegations.
Compliant LSP Agreement Structure
Properly structured Lending Service Provider agreements protect both the RE and the fintech LSP.
Data Privacy and DPDP Compliance
Digital lending data collection policies aligned with both RBI guidelines and DPDP Act 2023.
Borrower Grievance Redressal System
RBI-compliant grievance mechanism with 30-day resolution timelines as mandated.

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Service Price
₹19,999
Starting price · GST extra

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