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.

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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

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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)

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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

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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

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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

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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

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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