Disclose who the lender is
Regulated entities must publish the lending service providers (LSPs) and digital lending apps they work with, and LSPs must make clear which regulated entity they act for. In marketing terms, every ad destination and app store listing should let a borrower see the actual lender.
Key Fact Statement and all-in cost
Borrowers must receive a Key Fact Statement before signing, including the all-inclusive cost of the loan expressed as an annual percentage rate. Advertising that quotes only a flat or monthly rate, or hides fees, conflicts with the spirit of this requirement.
Data collection only with consent
Digital lending apps must collect only data that is needed, with prior explicit consent, and must not access phone resources like contacts or media files beyond permitted limits. Growth teams should audit SDKs, analytics events and form fields against this.
- Remove form fields you do not use for credit decisions.
- Make consent purpose-specific and recorded.
- Review third-party pixels on application pages.
Cooling-off and grievance
Borrowers get a cooling-off period to exit the loan, and each regulated entity and LSP must name a grievance redressal officer. Link these clearly from landing pages and app listings.
Frequently asked questions
- Do the Directions apply to a marketing agency?
- They apply to regulated entities and, through them, to LSPs. Agencies are not regulated directly, but the campaigns they run must keep their clients compliant.
- Is this legal advice?
- No. This is a marketing summary. Read the RBI Directions in full and consult your compliance team for decisions.
This guide is a marketing summary, not legal advice. Platform policies and regulations change; always confirm against the official source and your compliance team.