Delhi NBFC Compliance — RBI Digital Lending 2026 Complete Checklist

Delhi NBFC Compliance — RBI Digital Lending 2026 Checklist

RBI cancelled the Certificate of Registration of 3 Delhi-area NBFCs in 2025 for failure to comply with Digital Lending Directions. With annual inspection cycles now standard, every Delhi NBFC must verify its compliance status proactively.

Board-Level Policies (Mandatory)

• [ ] Board-approved Fair Practices Code — reviewed and adopted in last 12 months
• [ ] Board-approved KYC Policy — includes Video KYC (V-CIP) procedure
• [ ] Board-approved Data Privacy Policy — DPDP Act 2023 compliant
• [ ] Board-approved Grievance Redressal Policy — with TAT commitments
• [ ] Designated Nodal Officer for customer grievances — name published on website
• [ ] Board resolution authorising digital lending operations

KYC and Borrower Verification

• [ ] Video KYC (V-CIP) integration with certified vendor
• [ ] Aadhaar OTP eKYC through UIDAI-licensed provider
• [ ] PAN verification via Income Tax Department API
• [ ] Credit bureau integration (CIBIL, Equifax, or Experian)
• [ ] Liveness detection in V-CIP session
• [ ] KYC audit log with timestamp per borrower
• [ ] Periodic KYC refresh (risk-based)

Digital Lending Operations

• [ ] Fully digital loan application (no physical forms as primary)
• [ ] AI or rule-based credit scoring with explainability
• [ ] Key Fact Statement (KFS) generated per loan — shows APR, all fees
• [ ] Sanction letter digitally signed and stored
• [ ] Disbursement only to verified borrower bank account (Penny drop validated)
• [ ] No cash disbursement
• [ ] Repayment schedule shared at disbursement
• [ ] Borrower portal: loan balance, EMI schedule, statement, payment option

CIMS Reporting to RBI

• [ ] Monthly CIMS submission system active
• [ ] Borrower-wise data in RBI-prescribed format
• [ ] Pre-submission error validation
• [ ] Submission receipt archived
• [ ] Reconciliation of CIMS data with internal books

Grievance Redressal (Compulsory)

• [ ] Online complaint portal accessible from website
• [ ] Complaint acknowledgement within 48 hours
• [ ] Resolution within 30 days
• [ ] Escalation path to RBI Integrated Ombudsman documented
• [ ] Quarterly grievance report presented to Board
• [ ] Nodal Officer contact published prominently

Data Protection — DPDP Act 2023

• [ ] Data inventory: what personal data is collected and stored
• [ ] Explicit consent before data collection
• [ ] Data retention policy documented
• [ ] Right to erasure mechanism operational
• [ ] Data breach response plan: 72-hour notification
• [ ] Grievance Officer appointed and contact published

MICS Compliance Audit Service

MICS conducts a thorough NBFC compliance audit — reviewing software, policies, and operational procedures against this checklist.

Audit fee: Rs. 25,000 (includes report and remediation roadmap)

Book a compliance audit: +91 9355273535 | admin@mics.asia