The Reserve Bank of India, on 8 May 2025, issued the RBI (Digital Lending) Directions, 2025 — a comprehensive regulatory framework governing digital lending operations by all regulated entities (REs). The Directions mandate that all banks, non-banking financial companies, and other REs must report details of their Digital Lending Applications (DLAs) through the Centralised Information Management System (CIMS) portal, which became operational for reporting from 13 May 2025.
Background
The digital lending ecosystem in India has expanded rapidly, with a proliferation of lending apps and platforms offering credit products to consumers. While earlier RBI guidelines on digital lending were issued in 2022 following recommendations of a Working Group, these were in the form of separate guidelines applicable to different categories of regulated entities. The new Directions consolidate and strengthen the regulatory architecture into a single, unified framework applicable across the board.
The need for a unified code arose from concerns about transparency in lending operations, the role of intermediary platforms in loan origination, and the protection of borrowers against predatory lending practices through unregulated digital channels.
Key Provisions
The RBI (Digital Lending) Directions, 2025 introduce the following requirements:
Mandatory DLA reporting: All regulated entities must furnish details of their digital lending applications on the CIMS portal. The RBI will make the list of reported DLAs available on its website to enable customers to verify whether a particular app is associated with an authorised RE.
Reporting timeline: The CIMS portal became operational from 13 May 2025, with entities required to upload their initial data by 15 June 2025.
Multi-lender platform transparency: Where lending service providers (LSPs) aggregate loan products from multiple REs, new disclosure requirements ensure that borrowers are presented with clear information about the identity of the actual lender, the terms of the loan, and the role of the intermediary platform.
LSP compliance deadline: Lending service providers have until 1 November 2025 to comply with requirements relating to the presentation of multiple REs to borrowers on their platforms.
Grievance redressal: The Directions mandate establishment of designated grievance redressal mechanisms by both REs and LSPs for handling complaints arising from digital lending transactions.
Implications for Practitioners
The unified Digital Lending Directions represent a significant regulatory step for the fintech sector. Banks and NBFCs operating through digital channels must immediately assess their compliance posture and ensure that all lending apps are registered on the CIMS portal within the stipulated timeframe.
For lending service providers and fintech companies operating as intermediaries, the multi-lender platform disclosure requirements will necessitate changes to user interfaces and loan presentation workflows. The November 2025 deadline provides a reasonable transition period, but early compliance planning is advisable given the operational complexity of redesigning borrower-facing platforms.
Legal advisors to digital lending businesses should review existing arrangements between REs and LSPs to ensure contractual terms align with the new Directions, particularly around data sharing, borrower disclosures, and grievance handling. Non-compliance carries regulatory risk given the RBI's stated commitment to cleaning up the digital lending space.