Lenders Law

1. Introduction The RBI has, through its April 2026 draft directions , initiated a fundamental recalibration of the regulatory framework governing NBFCs. For NBFCs, this is not merely a consolidation of legacy circulars. It represents a transition toward a supervision-led regulatory architecture , with direct implications for governance, credit strategy, outsourcing models, and regulatory exposure. This blog examines key elements emerging from select draft directions and their implications for NBFCs, fintechs, and regulated entities. 2. Compliance Function: Institutionalizing Control at the Core of NBFC Operations The Reserve Bank of India (Non-Banking Financial Companies – Compliance Function) Directions, 2026 introduce: Annual Compliance Risk Assessment:  Senior management is required to conduct a formal, enterprise-wide compliance risk assessment and implement a mitigation plan. Chief Compliance Officer (CCO) Framework: Mandatory appointment of a CCO (including exter...

Prize-Linked Savings Accounts (PLS accounts), also known as  lottery-linked deposit accounts , are an innovative financial product designed to encourage savings by combining the  security of a traditional savings account  with the  excitement of a lottery-style reward . Instead of offering higher interest rates, these accounts provide depositors with a chance to win cash prizes—without risking their principal. Globally, PLS schemes have been used as a tool for  financial inclusion , particularly to attract individuals who may otherwise remain outside the formal banking system. However, their compatibility with India’s regulatory framework raises important legal and policy questions. What Are Prize-Linked Savings Accounts? A prize-linked savings account offers depositors an opportunity to participate in periodic prize draws based on the amount they save. The core idea is simple: Depositors place money into a savings account. Each qualifying deposit ...

The Reserve Bank of India (RBI) recently cancelled  the Certificate of Registration (CoR) of four Non-Banking Financial Companies (NBFCs). While CoR cancellations are not routine, they are a powerful supervisory tool used when an NBFC fails to comply with prudential, regulatory, or governance requirements. This development has again placed the spotlight on Section 45-IA(6) of the Reserve Bank of India Act, 1934 , the statutory basis for cancellation of an NBFC’s CoR. What Does Section 45-IA(6) of the RBI Act Provide? Section 45-IA deals with registration requirements for NBFCs . Sub-section (6) empowers RBI to cancel an NBFC’s CoR if it fails to comply with essential conditions. RBI may cancel the CoR if the NBFC: Fails to comply with conditions of registration; Does not maintain the prescribed Net Owned Fund (NOF); Fails to submit statutory returns or documents; Operates in a manner that is prejudicial to public interest; Violates RBI directions, circulars, o...

On 8 November 2025, the Securities and Exchange Board of India (SEBI) issued a strong cautionary advisory warning the public about the risks associated with Digital Gold/ E-Gold products offered on various digital platforms. This warning arrives at a time when fintech ecosystems are aggressively promoting digital gold through festive campaigns, ₹1 gold sales, jackpot offers, and even celebrity- driven, game show inspired advertisements . This widening gap between regulatory reality and advertising-driven perception demands a public conversation. 1. What SEBI Has Clarified: SEBI emphasizes that digital gold products: Not a security under the Securities Contracts Regulation Act (SCRA); Not a commodity derivative under the SEBI Act; Not an Electronic Gold Receipts (EGR) or Exchange Traded Funds (ETF) under relevant SEBI frameworks; Not issued by a government or regulated financial intermediary; SEBI has no jurisdiction over digital-gold issuers or platforms. This creates a regu...

With the evolution of technology, the way of executing documents have also evolved. With the increasing demand for modern, convenient methods for entering into binding transactions, electronic agreements and electronic signature have gained a lot of momentum in recent years. Technological developments have not only changed the ways in which these transactions are entered into but the execution process has also revolutionised significantly. Speaking about e- agreements, while there has been various case laws, wherein email between parties has also been accepted as a binding contract, the validity and enforceability of click- wrap agreements still continues to be a cause of concern. RBI's Working Group on Digital Lending, in its recent report dated 18.11.2021, has made far reaching recommendations on digital lending. In this video, the expert will speak about implications of the report for industry players, and his learnings/ suggestions.