BNPL Compliance in India: A Working Checklist
The question isn't whether a BNPL rule applies. It's what your product legally is.
RBI has never issued rules with "BNPL" in the title. Instead, BNPL products get pulled into whichever existing framework their structure actually matches, and that classification decision is where most compliance risk sits. This is a working reference, not legal advice.
Which framework your product actually falls under
| If the product is structured as... | Then it must comply with... |
|---|---|
| A revolving credit limit with an identification device | The Credit Card Master Directions, 2022, meaning NBFC issuers need prior RBI approval, as if issuing an actual credit card |
| A prepaid instrument (wallet) loaded via credit | Not permitted for non-bank issuers at all; RBI's June 2022 circular explicitly bars loading a PPI through a credit line |
| A real-time, single-purpose term loan | The Digital Lending Directions, 2025, same KFS, cooling-off, and LSP due-diligence rules as any other digital loan |
The June 2022 PPI circular is what actually forced the market's hand: it directly impacted Jupiter, Slice, LazyPay, Uni, MobiKwik, and several others, most of whom pivoted to co-branded cards issued with a bank partner, or to real-time term loans, rather than the credit-linked wallet model that had defined the category.
The practical takeaway
The compliance question isn't "does a BNPL rule apply to me," it's "which existing rule does my specific product structure fall under." Get the classification wrong and every downstream disclosure, approval, and reporting obligation is likely wrong too.
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