The hidden charges, real APRs, recovery harassment, CIBIL damage — and exactly what the RBI's newest rules say you're entitled to. No lender paid for this.
Written by: Team SahiSujhav Published: June 2026 · Reading time: 10 minutes Sources: All claims hyperlinked inline. Primary sources: RBI Digital Lending Directions 2025 (issued May 8, 2025); RBI Master Direction supplement, March 2026; CRIF High Mark, How India Lends — Q4 FY26, March 2026; DPDP Act 2023.
Already in a loan that feels unfair? Check if your APR is predatory and get a lender-ready letter in 2 minutes → Sahi Rate – Reset Karo
Considering a loan? See the true APR before you tap Accept → EMI Truth Calculator
Being harassed by a recovery agent? → Harassment Toolkit drafts your RBI complaint free
CIBIL damaged? → Recovery Plan gives you a 12-month roadmap
Before anything else — what changed in 2025 and 2026
Most articles about instant loan apps still cite the September 2022 RBI Master Direction. That framework no longer exists.
On May 8, 2025, the Reserve Bank of India issued the RBI (Digital Lending) Directions, 2025, which repealed and replaced the 2022 Guidelines in their entirety. These Directions came into immediate effect, with phased provisions through November 1, 2025.
On March 1, 2026, the RBI issued a Master Direction supplement that tightened the framework further — specifically prohibiting any fee not disclosed to the borrower at the time of sanction, with zero exceptions.
Why this matters for you: the rules protecting you are now stronger, more specific, and carry sharper enforcement teeth than anything that existed before 2025. If a loan app harassed you last year and you were told "nothing can be done," that may no longer be true.
This article is grounded in the 2025 Directions and the March 2026 supplement — the current law.
The scale of the problem — in data
As of March 2026, here is where India's personal lending market actually stands:
| Segment | Outstanding | YoY Growth | New volumes originated by NBFCs |
|---|---|---|---|
| Personal loans | ₹16.5 lakh crore | 12.9% | ~91% in Q4 FY26 |
| Consumer durable / BNPL | ₹1.0 lakh crore | 20.8% | ~88% |
| Gold loans | ₹18.6 lakh crore | 50.4% | 49% (rising) |
| Credit cards | ₹3.4 lakh crore | 0.0% | Banks only |
Source: CRIF High Mark, How India Lends — Q4 FY26 / March 2026.
The most important number: nine out of ten new personal loans by volume are now originated by NBFCs and the fintech apps that ride on their licenses.
The uncomfortable companion statistic: the sub-₹1 lakh personal loan segment — where virtually every instant loan app operates — carries the highest delinquency rate of any ticket-size band in Indian retail credit: PAR 91-180 at 2.27% as of March 2026. One in every 44 rupees lent in this segment is more than 90 days overdue.
The borrowers behind that 2.27% are not statistics. They are people with blocked CIBIL scores, collection calls arriving at 10 PM, and family members receiving threatening WhatsApp messages. Most do not know their rights. This article is for them.
Problem 1 — The "instant" loan is not what it appears to cost
Instant loan apps — including widely-downloaded platforms such as KreditBee, mPokket, Navi, MoneyView, CASHe, Fibe, Stashfin, True Balance, FlexSalary, Phocket, PayMe India, Olyv, PayRupik and others — market themselves with five consistent promises:
- ✅ Approval in 5 minutes
- ✅ No paperwork
- ✅ Money credited immediately
- ✅ Minimal documentation
- ✅ "Affordable" EMI
All five are technically accurate. None of them tell you the total cost of borrowing — which in regulatory terms is the Annual Percentage Rate (APR), inclusive of every fee, charge, and tax.
The gap between what the app shows and what you actually pay
Work through a real example:
| Step | What it looks like | What is actually happening |
|---|---|---|
| You apply for | ₹10,000 | ₹10,000 sanctioned |
| Processing fee | "₹500 (5%)" | Deducted upfront. You receive ₹9,500 in your account. |
| GST on fee | Often buried or not shown | ₹90 additional charge |
| Tenure | "30 days" | Real cashflow: -₹9,500 on Day 0 |
| Repayment | "₹11,500 in 30 days" | You repay ₹11,500 on Day 30 |
| Advertised cost | "3% / month" | Sounds like ₹300 |
| True APR (IRR method) | Not shown anywhere | ~276% per annum |
The true APR is computed using the Newton-Raphson Internal Rate of Return (IRR) method on the actual cashflow series — the method the RBI mandates lenders to use for rate disclosure under the 2025 Directions.
The advertised "3% / month" is calculated on the sanctioned amount (₹10,000), not the amount you actually received (₹9,500). The upfront fee, the GST on that fee, and the short 30-day tenure compound into a true annualised cost that is more than 90 times the headline number.
Rule of thumb before you borrow:
- True APR below 36% → prime-range pricing
- True APR 36–60% → subprime — evaluate carefully
- True APR above 100% → predatory in consumer-protection terms
Already in a loan that feels wrong? Use Sahi Rate – Reset Karo: enter your loan details manually or upload your loan terms, and within 2 minutes you get (a) the true APR on a four-band fairness scale and (b) the exact letter to send your lender — whether that's a formal review request, a grievance complaint, or a regulatory escalation to RBI Sachet. Free, no login, borrower-side only.
Considering a loan but not sure? The SahiSujhav EMI Truth Calculator computes the true APR for any loan in 30 seconds before you accept it.
Problem 2 — Hidden charges you weren't told about upfront
Borrowers most commonly report being surprised by charges that were not clearly visible during the application flow:
- Processing fees (2–6% of loan amount, deducted from disbursal — so you receive less than you applied for)
- Platform or convenience fees (often listed separately to make each look smaller than it is)
- GST at 18% on every fee component
- Late payment penalties (can reach 1% per day — equivalent to a 365% annualised penalty rate)
- Bounce charges (₹400–₹750 per failed auto-debit attempt)
- Pre-payment or foreclosure fees (2–5% of outstanding balance)
What the RBI's 2025 Directions and March 2026 supplement require from lenders
The burden of transparency sits with the lender, not the borrower. Under the RBI Digital Lending Directions 2025 and the March 2026 Master Direction supplement, every regulated lender is required to:
- Provide full fee and APR disclosure before disbursal — not at the time of repayment, not buried in fine print, not post-sanction
- Disclose the APR inclusive of all charges — not the headline monthly rate alone
- Never add a charge after sanction that was not disclosed upfront — "administrative charges" and "digital repayment convenience fees" added post-sanction are explicitly prohibited as of March 2026
- Provide a mandatory cooling-off period during which you can return the loan without full penalty
- Name a Grievance Redressal Officer — a real person with a published email and a 30-day resolution SLA
If you believe a charge was added to your loan without prior disclosure, that is a reportable violation. Use Sahi Rate – Reset Karo to document the actual APR on your loan and generate a formal letter to the lender's Grievance Officer — the required first step before escalating to RBI Sachet.
Problem 3 — Short tenures that create debt traps
Most instant loan apps offer repayment windows of 7, 14, 30, or 90 days. The arithmetic problem with short tenures is simple: even a modest fee becomes enormous when annualised.
A 5% processing fee on a 30-day loan is equivalent to paying 60% of the principal as fees alone per year — before any interest. Compress the tenure to 14 days and that figure doubles again.
How a borrower becomes trapped — a realistic scenario
- Takes ₹10,000 from App A. Receives ₹9,200 after fees. Must repay ₹11,800 in 30 days.
- Cannot repay in full. Takes ₹12,000 from App B to repay App A.
- App B's fees reduce disbursal to ₹10,800. Repayment: ₹14,000 in 30 days.
- Both loans now trigger credit bureau inquiries. CIBIL drops 15–30 points.
- App B also cannot be repaid. App C is tried — but CIBIL is now lower, so only the highest-APR apps approve.
- Borrower is now servicing 2–3 simultaneous loans with ₹35,000+ in repayment obligations on a principal of perhaps ₹10,000.
This pattern — documented by Deccan Herald (January 2025) and across hundreds of consumer complaint forum entries — is the most dangerous consequence of instant lending, and the one borrowers least recognise while they are inside it.
Can you negotiate a lower interest rate on an existing loan?
In some cases, yes. If your loan carries a true APR significantly above the market rate for your credit profile — and you can demonstrate this with a documented calculation — you have grounds to write a formal rate-review request to your lender.
Sahi Rate – Reset Karo was built specifically for this: it computes your true APR, benchmarks it against the RBI's published rate bands, and drafts a lender-ready letter requesting a rate reset or restructuring. Lenders are not legally obligated to agree, but a well-drafted, APR-documented grievance letter carries significantly more weight than a verbal request — particularly now that the 2025 Directions require lenders to respond to grievances within 30 days.
If you are in the debt-trap scenario above, the SahiSujhav CIBIL Recovery Plan walks through the math of which loans to settle, which to pay in full, and the realistic 9–12 month roadmap to rebuild.
Problem 4 — Aggressive recovery: what is legal and what is not
This is the section most borrowers need most urgently.
Under the RBI Digital Lending Directions 2025 and the Fair Practices Code for NBFCs, every borrower in India has the following specific, enforceable rights during the recovery process:
Your 10 RBI rights as a digital borrower in 2026
| # | Your right | What the rule says |
|---|---|---|
| 1 | Recovery contact only between 8am and 7pm | Calls or messages outside this window are a Fair Practices Code (FPC) violation — reportable to RBI Sachet immediately |
| 2 | No contact with family, friends, employer, or contact list | Lenders cannot shame you through your network. This was always an FPC violation and is now also a DPDP Act violation. |
| 3 | No abuse, intimidation, or threatening language | Verbal threats may additionally constitute an offence under Bharatiya Nyaya Sanhita §351 |
| 4 | No physical visit without prior written notice | And only at agreed times |
| 5 | Disclosure of recovery agent's identity before contact | Under the 2025 Directions, lenders must inform you of authorised recovery agents before they contact you |
| 6 | Full rate and fee disclosure before you accept the loan | APR, schedule, all charges — before disbursal |
| 7 | Mandatory cooling-off period | Right to return the loan within the specified window without penalty |
| 8 | Named Grievance Officer | A person, not an inbox. Published contact. 30-day resolution SLA. |
| 9 | Right to escalate to RBI after 30 days | If the lender does not resolve your complaint within 30 days, escalate to RBI Sachet or the RBI Ombudsman |
| 10 | No undisclosed post-sanction fees | As of March 2026: zero exceptions. Any charge added after sanction without prior disclosure is an illegal deduction. |
What to do if any of these rights have been violated
The SahiSujhav Harassment Toolkit maps your specific situation to the violated rule and drafts:
- A formal written complaint to the lender's Grievance Officer (required first step before any escalation)
- An RBI Sachet escalation if the lender does not respond within 30 days
- A National Consumer Helpline (1915) complaint for unfair charges
The toolkit is free, anonymous, and every upload is auto-purged from our servers within 30 days.
For criminal threats — intimidation, fake legal notices, morphed photographs — file at the National Cyber Crime Reporting Portal or call 1930. This is a criminal matter, not a consumer complaint.
Problem 5 — Contact access and the DPDP Act 2023
Several digital lending apps have historically requested access to a borrower's full contact list, SMS inbox, photo gallery, and location data — access used during recovery to contact and shame the borrower's network.
This practice is now explicitly illegal under two separate frameworks:
What the RBI 2025 Directions say
- Apps may collect only data necessary for the loan transaction — no broader purpose
- Explicit borrower consent is mandatory before any data collection — a bundled "I accept" does not meet the standard
- Apps are strictly prohibited from accessing contacts, call logs, or photo galleries
- Using borrower data without consent is a violation that can result in license cancellation for the lender
What the DPDP Act 2023 says
- Purpose limitation: data collected for a loan cannot be used for recovery or sold to third parties
- Right to erasure: once your loan is closed, you can demand deletion of your data
- Named Grievance Officer (§13): a real person with a published contact — required of every data processor
- Consent is specific, informed, and revocable at any time
Before installing any loan app, open its Play Store or App Store listing and check the permissions it requests. If the app asks for Contacts, SMS, or Gallery access — that is a regulatory violation for any collection-related purpose. You can raise this directly at RBI Sachet.
Problem 6 — CIBIL score impact: even ₹3,000 matters
One of the most expensive misconceptions in instant lending: "it's a small loan — missing one payment won't matter."
It will. Here is exactly why.
Under Section 21 of the Credit Information Companies (Regulation) Act, 2005, every regulated lender is legally required to report your repayment behavior to all four credit bureaus — CIBIL, Experian, Equifax, and CRIF High Mark — regardless of loan size.
A 30-day delinquency on a ₹3,000 loan is recorded with the same data structure as a 30-day delinquency on a ₹30 lakh home loan.
The specific consequences
| Delinquency stage | CIBIL impact | Duration on report |
|---|---|---|
| 30 days late | 30–50 point drop | 7 years |
| 60 days late | 50–80 point drop | 7 years |
| 90+ days late | 80–120 point drop | 7 years |
| Settled (paid less than full amount) | "Settled" tag — treated worse than late payment by most prime lenders | 7 years |
| Written off | Worst CIBIL outcome short of home loan default | 7 years |
CRIF High Mark's March 2026 data shows that the sub-₹1 lakh personal loan segment carries PAR 31-90 at 2.04% and PAR 91-180 at 2.27% — the highest delinquency in the entire retail credit pyramid.
The downstream consequences include: prime-lender loan rejections for 12–24 months; credit card applications declined; higher interest rates on future approvals; home loan eligibility affected below 680–700 CIBIL.
If you are already in a damaged CIBIL position, the SahiSujhav CIBIL Recovery Plan gives you a band-based 12-month roadmap, a settlement-vs-full-payment calculator, and a dispute letter generator for bureau errors.
Problem 7 — Multiple applications hurt you before you even borrow
Borrowers under financial pressure often apply to 5–8 apps simultaneously. Each application typically triggers a hard credit inquiry:
- Each hard inquiry reduces your CIBIL by 3–10 points
- Multiple inquiries within 30 days signal "credit-hungry" behavior to risk algorithms
- Prime lenders may decline you on this basis alone
- You are then pushed toward higher-APR fallback lenders
Rule: apply to a maximum of 2 lenders in any 30-day window. Use SahiSujhav App Reviews to pre-screen and shortlist before you apply — each app's RBI registration status, APR range, and complaint patterns are documented with no referral commission from any of them.
Problem 8 — The re-engagement trap for young borrowers
Students and first-time salaried employees are the demographic most targeted by instant lending apps — and the least equipped to evaluate total loan cost.
The structural problem is that these apps are built for re-engagement — the same UX pattern as social media and gaming. Pre-approved offers, "your credit limit was increased," "borrow more with one tap" — designed to keep users borrowing, not to help them evaluate whether they should.
Under the 2025 Directions, lenders are now prohibited from pushing unsolicited pre-approved loan offers or collecting data for that purpose without explicit consent. If an app is sending you loan-offer notifications you did not request, that is a violation.
Common use cases that become debt spirals: bridging a salary gap, gadgets and lifestyle spending, repaying a previous loan. In each case, Sahi Rate – Reset Karo can show you — in writing — whether the rate on that loan is fair before you decide to take more.
Problem 9 — Mental health: the invisible cost
Financial stress from a debt cycle is among the leading drivers of mental health deterioration in working-age Indians. Borrowers commonly describe:
- Anxiety and disrupted sleep from constant payment reminders
- Social withdrawal to avoid explaining the situation to family
- Workplace distraction and falling performance
- In serious cases: suicidal ideation, particularly when harassment escalates
This is not a character failing. It is a predictable human response to a system designed to extract money under time pressure from people who were already financially stressed.
If you are experiencing this, please reach out:
- iCall: 9152987821 — Mon–Sat, 8 AM–10 PM, free, confidential, multiple Indian languages
- Vandrevala Foundation: 1860 2662 345 — 24/7
- Tele-Manas (Government of India): 14416 — 24/7, free
A "Settled" tag on your CIBIL recovers in 7 years. You do not.
How to check if a loan app is RBI registered — step by step
Before downloading or applying on any loan app, spend 3 minutes on this:
Step 1 — Find the lender's legal name in the app's Play Store or App Store listing. Look for "In partnership with" or "Lending partner." The underlying NBFC or bank must be named. If no lender is named, stop here.
Step 2 — Search for that exact name on the RBI NBFC Registry. The name must match exactly. Partial matches or abbreviations are not acceptable.
Step 3 — Verify the status shows as "Active." RBI registration can be cancelled. An entity that was registered a year ago may not be now.
Step 4 — Check the app's Privacy Policy for a named Grievance Officer. Under DPDP Act §13, there must be a real person named — not just an email address.
Step 5 — Read the 1-star reviews on the Play Store sorted by Most Recent. Sort by newest, read the last 90 days. Patterns in recent reviews are more informative than the overall star rating, which can be inflated by older reviews.
The SahiSujhav App Reviews directory has done this work for 12 widely-downloaded apps — RBI registration, APR ranges, complaint patterns — with no referral commissions from any app on the list.
If you're already in a high-APR loan — can you reduce the rate?
This is the question most borrowers don't know to ask.
The answer is: sometimes yes, and it's always worth trying if your rate is predatory.
Under the 2025 Directions, lenders must respond to formal borrower grievances within 30 days. A well-documented rate-review request — one that shows the lender their own APR, benchmarks it against the RBI's rate bands, and formally requests restructuring or a rate reset — is not guaranteed to succeed, but it puts your request on a legal track with a response obligation.
Sahi Rate – Reset Karo was built for exactly this:
- Enter your loan details manually (amount received, total repayment, tenure, fees) or upload your loan summary document — the tool auto-fills your terms
- It computes your true APR using the IRR method
- It places your APR on a four-band fairness scale: Fair / Borderline / High / Predatory
- It drafts the right letter for your situation:
- Rate review request — for lenders where restructuring may be possible
- Formal grievance — if the rate or fees were not disclosed upfront as required by the 2025 Directions
- RBI Sachet escalation — if the lender doesn't respond within 30 days
No login. No commission. No data shared. Borrower-side only.
The letter is drafted in the regulatory language lenders take seriously — citing the specific RBI Directions applicable to your complaint, not a generic "I want a lower rate" request.
If the lender agrees to restructure, the interest saving on even a moderately predatory loan can be significant: on a ₹50,000 loan running at a true APR of 180% vs a restructured 36%, the difference over 12 months is roughly ₹36,000 in interest charges. That calculation is what the letter is built on.
Your action plan right now — 9 steps
Whether you're considering an instant loan, currently servicing one, or already in difficulty:
1. Before borrowing — run the EMI Truth Calculator. Enter the amount you'll actually receive, the repayment, and the tenure. If the true APR is above 36%, make that a conscious decision — not a surprise you discover later.
2. Already in a loan that feels wrong — use Sahi Rate – Reset Karo. Get your true APR on a fairness scale. Get the lender-ready letter. Takes 2 minutes.
3. Verify the lender on the RBI NBFC Registry. Takes 2 minutes. Non-negotiable.
4. Apply to maximum 2 lenders in any 30-day window. Use SahiSujhav App Reviews to shortlist before applying.
5. Document everything from Day 1. Every call: date, time, caller number, what was said. Every message: screenshot with timestamp. Call recordings are legal in India when you are a party to the call.
6. If harassment has started — Harassment Toolkit first. Formal complaint to the lender's Grievance Officer is the required first step. If unresolved in 30 days: RBI Sachet. If criminal threats: cybercrime.gov.in or call 1930 immediately.
7. For unfair charges — National Consumer Helpline: 1915 or consumerhelpline.gov.in.
8. For CIBIL recovery — CIBIL Recovery Plan. Dispute-vs-pay math, 12-month roadmap, what "Settled" actually costs you vs paying in full.
9. Ask HeyZ. HeyZ is SahiSujhav's AI borrower assistant, grounded in RBI rules, DPDP, and the BNS. Every factual answer it gives cites the underlying source. AI, not a lawyer — but faster than a Google search at 11 PM when recovery calls have stopped and you're trying to figure out what to do next.
Frequently asked questions
Q: Are all instant loan apps unsafe? No. Many apps are operated by or in partnership with RBI-registered NBFCs that follow the 2025 Directions. The risk is concentrated in apps operating outside the regulatory framework entirely, and in regulated apps where charges are not disclosed upfront as required. The SahiSujhav App Reviews directory rates 12 apps independently.
Q: What is a true APR and why does it matter more than the advertised rate? APR (Annual Percentage Rate) is the total yearly cost of credit — interest plus every fee, charge, and tax — as a single number. A "5% processing fee on a ₹10,000 loan repayable in 30 days" works out to over 60% APR from the fee alone. The 2025 Directions require lenders to disclose APR inclusive of all charges before you accept the loan. Compute it for any loan using the SahiSujhav EMI Truth Calculator or Sahi Rate.
Q: What is the RBI Digital Lending Directions 2025? The RBI Digital Lending Directions 2025 (issued May 8, 2025) is the current regulatory framework for all digital lending in India. It replaced the 2022 Master Direction entirely. It applies to all regulated entities — banks, NBFCs, Housing Finance Companies — and their lending partners. If the app you're using is backed by any regulated entity, these Directions apply to it.
Q: Can a recovery agent call my family or employer? No. Under the RBI Fair Practices Code, incorporated into the 2025 Directions, recovery agents cannot contact family, friends, employer, or anyone from your contact list for recovery or shaming purposes. This is also a DPDP Act violation. Document the incident. File with the lender's Grievance Officer first. Escalate to RBI Sachet at 30 days.
Q: Can I get my loan interest rate reduced? In some cases, yes. If your loan carries a true APR significantly above fair-market benchmarks, you can submit a formal rate-review or restructuring request to the lender. Sahi Rate – Reset Karo computes your true APR and drafts this letter for you — in regulatory language, citing the specific RBI Directions that apply to your situation. The lender must respond within 30 days.
Q: Can I cancel a digital loan I just took? Under the 2025 Directions, every digital loan must include a mandatory cooling-off period during which you can return the loan without full penalty. The duration must be disclosed before you accept. If you've just taken a loan and changed your mind, check your loan agreement immediately and look for the cooling-off terms.
Q: Does a missed payment on a small loan really damage my CIBIL? Yes. Under Section 21 of the Credit Information Companies (Regulation) Act 2005, all regulated lenders must report repayment behavior regardless of loan size. A 60-day delinquency on a ₹5,000 loan can reduce your CIBIL by 50–100 points and remains on your report for 7 years.
Q: What is the lowest legitimate APR on an instant loan in India in 2026? Per CRIF High Mark's March 2026 data, bank-led personal loans begin around 10–13% APR for prime borrowers. NBFC-led digital loans typically range 14–28% APR. Instant apps in the sub-₹1 lakh, 7–30 day space routinely carry true APRs of 100–400%. Anything above 36% is subprime pricing. Anything above 100% is predatory in consumer-protection terms.
Q: What if I'm in emotional distress because of loan harassment? Please call iCall: 9152987821 (free, confidential, multiple languages, Mon–Sat 8 AM–10 PM), Vandrevala Foundation: 1860 2662 345 (24/7), or Tele-Manas: 14416 (24/7, Government of India, free). The financial situation is solvable. You are not replaceable. Please reach out.
Q: Is SahiSujhav a lender? No. SahiSujhav is an independent borrower-side information platform. We do not originate loans, broker loans, or take referral commissions from any lender — including the ones reviewed on our platform. Full disclosure at sahisujhav.com/disclosures.
A note on the apps mentioned in this article
We have named KreditBee, mPokket, Navi, MoneyView, CASHe, Fibe, Stashfin, True Balance, FlexSalary, Phocket, PayMe India, Olyv, and PayRupik as widely-downloaded examples of instant lending apps operating in India. This article is a category-level analysis of the regulatory framework and borrower-reported experiences in this category.
It is not a determination of any specific app's compliance status or a finding of wrongdoing against any named platform.
For app-by-app analysis — RBI registration, APR ranges, and patterns observed in public user complaints — see our App Reviews directory. Each review names the reviewer, the last-verified date, all sources, and includes a documented right-of-reply invitation to the lender. Lenders can submit responses at hello@sahisujhav.in.
About this article
Editorial methodology: /transparency · Disclosures: /disclosures · Corrections: hello@sahisujhav.in — we publish a correction log.
This is information, not legal or financial advice. Readers considering legal action, facing harassment, or making significant financial decisions should consult a registered advocate, financial advisor, or the relevant regulatory body.
Related on SahiSujhav: Sahi Rate – Reset Karo · EMI Truth Calculator · App Reviews Directory · Harassment Toolkit · CIBIL Recovery Plan · HeyZ AI Assistant · RBI Sachet Complaint Guide · Recovery Agent Rights · CIBIL After Loan Settlement
Dev team — publish checklist (remove this block before going live)
URL slug: /blog/instant-loan-app-problems-india-2026
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Quarterly refresh: Update CRIF High Mark data table when Q1 FY27 report publishes (expected July 2026). Bump "Last updated" date to trigger re-indexation.