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In September 2022, the Reserve Bank of India issued a landmark circular that changed digital lending in India. The guidelines — officially RBI/2022-23/111 — created the most comprehensive borrower protections the country had ever seen for digital loans.
Most borrowers have never heard of them. Lenders are required to follow them. This article translates them into plain language — your 10 essential rights.
Right 1: The Key Facts Statement (KFS)
Before any digital loan is disbursed, you must receive a KFS — a plain-language document showing your loan's APR, all charges, your EMI, total repayable amount, and grievance contact. This must be accepted by you before money is sent.
If you didn't receive it: This is a violation. File with RBI Sachet.
Right 2: APR Must Be Disclosed
The KFS must show your Annual Percentage Rate — the all-in cost including all fees. Not just the monthly rate. Not just the daily rate. The full APR.
Why it matters: APR is the only honest comparison metric. "0.5% per day" sounds cheap; "182% APR" is the same number.
Right 3: Three-Day Cooling-Off Period
After your loan is disbursed, you have 3 business days to cancel. If you cancel within this period: The loan is reversed You repay only the principal + pro-rata interest for days used No penalty, no foreclosure charge
How to exercise: Write to the lender within 3 business days of disbursement: "I wish to cancel loan account [NUMBER] under the RBI Digital Lending Guidelines cooling-off provision."
Right 4: No Unauthorised Data Access
Loan apps may access only data necessary for the specific service — and only with your explicit consent for each type of data. Apps cannot access your full contact list, photos, or other sensitive data as a condition for loan approval.
Violation indicator: Any app that demands contacts/photos access at signup (not during identity verification) may be setting up for harassessment-based collection.
Right 5: No Third-Party Recovery Contact
Recovery agents may contact only you — not your family, employer, colleagues, or anyone in your contact list (except named guarantors).
If your contacts are called or messaged: This is a clear violation of RBI guidelines. File with RBI Sachet + Cybercrime Portal.
Right 6: RBI-Regulated Lending Only
Digital loans must be extended only by entities registered with RBI as banks or NBFCs. Third-party apps that are the "face" of the loan must be partnered with an RBI-registered entity — the regulated entity's name must appear prominently in the app and loan documents.
If you cannot find an RBI registration number: The app may be illegal.
Right 7: No Automatic Credit Limit Increase
Lenders cannot increase your credit limit without your explicit consent. Pre-approved limit increases sent by SMS that automatically apply if you don't opt out are not permitted.
Right 8: Clear Grievance Mechanism
Every digital lender must have: A Nodal Officer with publicly available contact details An in-app complaint mechanism RBI Sachet and Ombudsman details displayed
If a lender has no visible Nodal Officer: This is a regulatory violation.
Right 9: Fair Recovery Practices
Recovery must comply with RBI's Fair Practices Code: Calls only 8 AM to 7 PM No abusive language No misrepresentation of authority No contact with third parties Recovery agents must carry ID
Right 10: Loan Account Portability
While not yet fully implemented, RBI's framework includes provisions for borrowers to transfer loans between lenders — facilitating rate competition. As this develops, SahiSujhav will publish guides on exercising this right.
The Bottom Line
You have more rights as a digital borrower than most people in India know. SahiSujhav exists to ensure you know every one of them — and can exercise every one of them, for free, with HeyZ AI's help.
Ask HeyZ AI about any specific right under RBI's Digital Lending Guidelines — free at www.sahisujhav.com
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