How RBI’s tightening grip on digital lending and payment aggregators is reshaping the fintech compliance playbook

The stringent regulations from the Central Bank of India are proving instrumental in reshaping the fintech ecosystem in the country.

The Reserve Bank of India (RBI) continues to keep a close watch on the fintech sector. Especially its special focus on the digital lending platforms and the payment aggregators has sharpened of late. RBI’s mandates are redefining compliance, and for the businesses in these sectors, it has become mandatory to not just adjust operations but also get aligned with new regulations. Now, with the Budget 2026 policy announcements, the RBI is heading towards creating a more tightly controlled, regulated financial environment. The responsible digital finance implementation, together with improved consumer protection measures and enhanced payment system supervision, as well as digital credit monitoring, will usher in a new era post-Budget 2026.

Adv. Siddhant Dhingra
Senior Partner
Foresight Law Offices India

RBI’s Evolving Regulatory Lens

Of late, RBI has changed gears – shifting its attention from defensive measures to a more demanding supervisory role. Among others, the issuance of the Digital Lending Guidelines (2022) and the establishment of regulations for payment aggregators and payment gateways are significant steps taken by India’s Central Bank. These steps underscore the RBI’s focus on enhancing transparency, accountability, and consumer protection, which must undergird the operations of fintech companies. The RBI Digital Lending Guidelines and payment aggregators’ mandatory authorisation system now function within the established framework of fiscal policy implementation. The two elements establish three essential rules which require organisations to disclose their pricing information and share their responsibility for business relationships, thereby safeguarding customer information. Under the current framework:

  • All digital loans must be disbursed and repaid through bank accounts of regulated entities.
  • Lenders are obligated to reveal all fees at the beginning, ensuring that the borrowers are well aware of the total costs.
  • The third-party lending applications can only be in the market if the backing is from an RBI-licensed lender.

These changes have turned compliance into a strategic necessity. For fintechs, meeting regulatory expectations without engaging in continuous legal monitoring and documentation has become very challenging. No wonder the space is witnessing the emergence ofspecialised NBFC compliance consultants and SEBI and RBI compliance lawyers. In addition, specialised corporate tax advisory legal services excelling in the Fintech domain are also taking a crucial position in assisting companies to cope with the changing reporting standards, partnership models, and consumer data policies.

Payment Aggregators: The New Custodians of Trust

Payment aggregators (PAs) have turned into the key players in online transactions in retail, e-commerce, and financial services. Considering their central role in the system, RBI has introduced stricter authorisation requirements for PAs, making compliance a must for continuing operations. As an effort to shield the national economy from payment security threats, the RBI is implementing more stringent payment authorisation norms and continues to stress the compliance obligations. The Union Budget of 2026 features support for the payment security systems as an initiative against any fraud within its policy framework. The following were among the main requirements:

  • Merchants can only be obtained by authorised PAs, and they shall be the only ones to handle customer funds.
  • The escrow account conditions have been made more stringent in order to guarantee the integrity of the funds.
  • Technology audits and cybersecurity certifications are now part of the requirements to reduce the risks of fraud.

With these changes, it has become clear that the fintechs will not be able to rely anymore on just their technological agility – they will have to build regulatory resilience into their business models right from the start. This explains the rise of many NBFC legal compliance consultants, strategic advisory service firms and M&A lawyers for financial institutions that today handle the complex requirements of PAs and financial institutions. Many corporate tax advisory legal services are also helping fintechs manage restructuring, funding, and acquisition decisions aligned with the RBI’s stringent guidelines.

Ripple Effect Across Sectors

Although the RBI’s restrictions are mainly aimed at the fintech sector, the ensuing ripple effects also have a bearing on insurance and health care domains. These are sectors where digital platforms are swiftly melding together financial services. In the insurance space, digital intermediaries which allow instant policy issuance or collection of premiums would straddle several regulators. When acting as facilitators of payments, they need to adhere not only to the insurance regulations but also to the norms for payments and settlements set by the RBI. These intermediaries will now have to follow the rules set by both the Investment and Insurance Regulatory and Development Authority of India (IRDAI) and the RBI when acting as payment facilitators. Clearly, the need for insurance policy drafting legal experts and regulatory compliance lawyers is felt irrespective of the size and scale of the insurtech firms. 

Healthcare-linked fintechs face an even more complex compliance matrix. Platforms providing health loans, wellness financing, and subscription telemedicine services must align their businesses to RBI financial guidelines while keeping within the contours of the Digital Personal Data Protection Act (DPDP Act, 2023). Expert support from healthcare regulatory compliance lawyers and healthcare data privacy law firms is critical to maintain lawful data sharing between lenders, insurers, and medical institutions. Further, the need for legal advisory for hospitals and wellness centres is becoming a matter of strategic necessity nowadays.

Conclusion: Future of Accountable Innovation

Regulatory tightening by RBI is not a barrier to innovation but rather an invitation to responsible growth. Fintech firms that see compliance as a competitive advantage will not only win consumer trust but will also get investment that is good for the environment. The blending of financial and non-financial ecosystems will make legal agility the distinguishing feature between the market leaders and the laggards.

Authored By: Adv. Siddhant Dhingra, Senior Partner, Foresight Law Offices India

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