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Credit analysts working on app-based loans need to know which RBI digital lending rules affect the credit file.
The 2025 Directions require direct fund flows, a key fact statement with the annual percentage rate, a cooling-off exit and consent-based, need-only data collection.
Keep on file the key fact statement, proof of disbursal to the borrower's own account, the consent trail for any data used and the cooling-off terms.
A credit file that shows the loan was priced, disclosed, funded and assessed in line with the Directions.
The RBI’s digital lending rules make the regulated lender, such as a bank or NBFC, answerable for every loan sold through an app. Money must move directly between the lender and the borrower, the full cost must sit in a key fact statement, borrower data needs consent, and the borrower gets a penalty-free cooling-off exit.
The current text is the Reserve Bank of India (Digital Lending) Directions, 2025, issued on 8 May 2025. It replaced the guidelines of 2 September 2022, with some parts taking effect later in 2025. This page is a plain summary; check the current text on rbi.org.in before relying on any clause.
What must the borrower be told before signing?
Before the borrower signs, the lender must give a key fact statement (KFS), a standard one-page style summary. It includes:
- The loan amount and tenure.
- The annual percentage rate (APR), which rolls interest and fees into one yearly cost figure.
- The repayment schedule, penal charges and recovery arrangements.
- The cooling-off period, during which the borrower may exit by repaying the principal and the proportionate APR without a penalty. The lender’s board decides the length, but it cannot be less than one day.
- The grievance officer’s contact details.
Any fee not shown in the KFS cannot be charged later.
What may a lending app collect, and what is off limits?
| Rule | What it means for the credit file | What the analyst should see on file |
|---|---|---|
| Direct fund flow | Disbursal goes to the borrower’s own account; repayment goes straight to the lender | Disbursal UTR matching the borrower’s account |
| Need-based data | Only data required for the loan, with explicit consent | A consent record naming purpose and data |
| No phone resources | No access to files, media or contact lists | App permissions limited to onboarding needs |
| KFS before signing | Full cost disclosed upfront | Signed KFS with the APR |
| Cooling-off exit | Penalty-free exit window | Cooling-off terms in the KFS |
| Grievance redress | Named grievance officer | Contact details in the KFS and app |
For bank statement data, consent usually comes through an Account Aggregator, which leaves a clear record. The parts of that consent are explained in what you agree to with an AA consent.
Worked example: a ₹1,50,000 app loan
A borrower takes a ₹1,50,000 personal loan through a lending app partnered with an NBFC, for 12 months.
- Interest is 18 percent a year on a reducing balance, giving an EMI of about ₹13,752 and total interest of about ₹15,024 (₹13,752 × 12 = ₹1,65,024, less ₹1,50,000).
- A processing fee of ₹3,000 plus 18 percent GST of ₹540 is deducted at disbursal, so ₹1,46,460 reaches the borrower.
- The KFS shows the fee, the EMI and an APR that is higher than 18 percent because it includes the ₹3,540 deducted upfront.
- The ₹1,46,460 lands in the borrower’s own savings account, not the app’s account, and the disbursal reference appears in the NBFC’s records.
If the borrower exits within the cooling-off period, they repay the principal plus the proportionate APR for the days used. The lender may keep the disclosed one-time processing fee if the KFS says so.
The analyst’s file should hold the signed KFS, the disbursal proof, the consent used for any bank statement data and the statement review itself.
Why does this matter for bank statement review?
Two links matter. First, data used for credit, including bank statements, must come with consent and a stated purpose. Second, the analyst’s statement review becomes evidence that the lender assessed repayment capacity, not just collected data. Bank statement analysis vs bank statement audit explains that difference, and predatory lending app detection shows what unregulated app loans look like inside a borrower’s statement.
What to read next
- Next in this series: Predatory lending app detection in India
- Bank statement analysis vs bank statement audit
- Bank statement analysis for digital lenders
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