A document checklist for RBI’s Digital Lending Directions
The Directions turn disclosure into a per-loan documentation obligation. This is a practical checklist for NBFC operations teams.
The Reserve Bank of India's Digital Lending Directions consolidate the rules that govern loans originated through digital channels. For an NBFC operations team, the practical effect is that every loan now carries a documentation obligation that can be audited line by line. The cost of getting it wrong ranges from supervisory findings to borrower complaints that escalate to the RBI Ombudsman.
The documents that matter
The Key Fact Statement. Every digital loan requires a KFS disclosing the annual percentage rate, all fees and charges, the recovery mechanism, and the grievance redressal contact. The APR must reflect the all-in cost of credit, including processing fees and insurance premiums where bundled. A KFS that omits a fee that later appears in the loan account is the single most common and most easily avoided finding.
The sanction letter. The sanction letter must be consistent with the KFS. Differences in rate, tenor, or fee schedule between the two documents are treated as disclosure failures, not clerical errors.
Consent records. Consent for data access must be specific and logged. Blanket consent for unrelated data is not acceptable. The log must show what was consented to and when.
The grievance register. Complaints must be resolved within 30 days. After that, the borrower can escalate to the RBI Ombudsman. The register needs a per-complaint clock, not a monthly summary.
A working checklist
| Check | Frequency | What to verify |
|---|---|---|
| KFS completeness | Every loan | APR present; fee schedule complete; recovery mechanism and grievance contact stated |
| KFS vs sanction letter | Every loan | Rate, tenor, fees identical across both documents |
| Fund-flow compliance | Every loan | Disbursal and repayment flow directly between borrower and the regulated entity's account |
| LSP disclosure | Per partner | Loan service providers and their fees disclosed to the borrower |
| Cooling-off terms | Every loan | Cooling-off period stated and operationally honoured |
| Grievance ageing | Weekly | No complaint approaching the 30-day boundary without an owner |
| Sample audit | Monthly | Random sample of loan files re-checked end to end |
Why sampling is not enough on its own
Most lenders run monthly samples of 50 to 100 files. Sampling finds systematic template errors well. It finds per-loan drift poorly: the loan where an operations executive edited a fee by hand, or where a partner's integration sent an older KFS template for three days. Catching those requires checking every file, which is only economical if the checking is automated. Document extraction has reached the point where APR presence, fee-table completeness, and KFS-to-sanction consistency can be verified on every loan rather than a sample.
Summary
Treat the Directions as a per-loan data quality problem. Define the checks as rules, run them on every file at origination, keep the evidence, and let the monthly sample audit verify the checker rather than the loans.