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Your rights under RBI's Digital Lending Guidelines (2022)

A plain-English guide to RBI's 2022 Digital Lending Guidelines and the rights every Indian borrower has.

VS
By Vikram Sharma · Borrower-Rights Writer
8 minPublished 6 Jun 2026Updated 5 Jun 2026

Your rights under RBI's Digital Lending Guidelines (2022)

RBI's 2022 Digital Lending Guidelines (DLG) are the strongest borrower-protection framework India has ever had for app-based lending. Every regulated lender — bank, NBFC, or fintech partner — must comply. Here's what they entitle you to.

Right 1 — A Key Fact Statement, before disbursal

The lender must show you a one-page KFS with the loan amount, APR, tenure, EMI, total interest, and all fees — before you accept. If you only see the EMI and not the APR, that's a violation.

Right 2 — Direct disbursal to your bank account

The loan must be credited directly to your bank account (or a verified UPI ID linked to your bank). Disbursal to a wallet, prepaid card, or third-party account is illegal under the DLG.

Right 3 — A cooling-off period

You can repay the loan within the cooling-off window (1–3 days, depending on lender) and pay only the proportionate APR — no penalty, no processing fee retention. The cooling-off window must be disclosed in the KFS.

Right 4 — Named, regulated lender on every screen

The app must clearly display the legal name of the RBI-regulated lender (bank/NBFC) on the loan agreement, KFS, and grievance page. "In partnership with leading NBFCs" is not enough.

Right 5 — A grievance officer who actually responds

The lender must publish the grievance officer's name, email, phone, and address. They have 30 days to resolve your complaint before you can escalate to the RBI Ombudsman.

The DLG bans loan apps from accessing your phone book, photo gallery, SMS, or call log. They can only access camera, mic, and one-time location for KYC. If the app demands more, uninstall.

Right 7 — Right to be deleted

You can ask the lender to delete your personal data after the loan is closed (subject to the lender's regulatory retention obligations). Request in writing; they must respond within 30 days.

Right 8 — Recovery within Fair Practices Code limits

Recovery agents must follow RBI's Fair Practices Code — no calls outside 8 am–7 pm, no contact with your family or employer, no threats. Violations are reportable to RBI Sachet and local police.

What to do if a lender violates any of these

FAQ — Digital Lending Guidelines

Q: Do these rules apply to bank-issued personal loans too? Yes — every regulated entity (banks, NBFCs, HFCs) issuing digital loans must follow the DLG. The rules are most strict for app-based and white-label lending, but the core entitlements (KFS, cooling-off, direct disbursal) apply across all digital channels.

Q: What is the difference between APR and "interest rate"? APR includes interest, processing fee, GST, and every other mandatory charge — annualised. "Interest rate" is just the headline number. The DLG mandates APR disclosure specifically to prevent the "low monthly rate" trick that loan apps used pre-2022.

Q: Can lenders share my data with credit bureaus without consent? Yes — once you accept the loan, sharing with CIBIL/Experian/Equifax/CRIF is implicit. What they cannot do is share with marketing partners, data brokers, or other lenders without explicit, separate consent. The DLG made this distinction enforceable.

Q: Does the cooling-off period cost anything? Proportionate APR + processing fee for the days you held the loan. Example: 3-day cooling-off used after 1 day → 1/14 of a 14-day loan's interest + a small portion of the processing fee. Many lenders waive even this for goodwill.

Q: What if the lender's grievance officer ignores me? 30-day deadline. After that escalate to the RBI Banking Ombudsman (cms.rbi.org.in) with original complaint date, lender's silence, and all evidence. Ombudsman decisions are binding and lenders comply quickly to avoid supervisory action.

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