RBI Digital Lending Directions 2025: DLA Reporting on CIMS

The Reserve Bank of India consolidated digital lending norms in 2025 into a single directions framework, replacing fragmented circulars. Every Digital Lending App (DLA) visible to Indian borrowers must now be reported on RBI's CIMS portal, with ongoing attestation of compliance.

Core architecture requirements

• Direct disbursement: Loan proceeds must flow directly from lender bank account to borrower account without pass-through LSP wallets
• Key Fact Statement (KFS): Standardised APR disclosure including all fees, insurance, and third-party charges
• Cooling-off period: Borrower exit without penalty within disclosed window
• No automatic credit line increases without fresh consent and KFS

CIMS reporting obligations

Regulated entities and their LSP partners must register each live DLA on CIMS with:

• App package name / web URL and version history
• Lender–LSP arrangement and role delineation
• Grievance escalation matrix
• Data access permissions requested by the app

Material updates (new data hooks, UI flows affecting disbursement, change of LSP) require within 7 days portal update.

LSP economics and transparency

LSP fees must be paid by lenders, not deducted opaquely from borrowers. Directions prohibit disguised charges through "platform fees" bundled into EMI without KFS line items.

Outsourcing and data

Cloud and analytics outsourcing must stay within RBI-approved jurisdictions where applicable. Lenders remain liable for LSP data breaches and must maintain audit trails of every bureau and alternative data pull.

Compliance calendar

1. Complete CIMS registration before marketing spend scales
2. Quarterly board compliance certificate on DLA portfolio
3. Annual penetration test summary upload where directed

SB Tech Associates supports NBFCs and fintech LSPs on CIMS filings, lender agreements, and inspection readiness. Request a briefing.