finpeel Answers · India · updated 2026-08-14
Generally not as a pass-through pool for ordinary digital-loan repayments. RBI’s digital-lending framework requires disbursal and repayment flows to move directly between the borrower and the regulated entity’s account, subject to specified exceptions.
The rule is designed to prevent unregulated LSPs from controlling borrower funds merely because they operate the app.
Design payment flows so the LSP does not become an unauthorised collection account or intermediary unless an express permitted exception applies.
Regulator: Reserve Bank of India (RBI)
Primary sources: RBI — Digital Lending Guidelines / FAQs · RBI — Digital Lending Directions, 2025
Directional — not legal advice. Verify with the regulator before committing.
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