Industry Practice · Delhi NCR
Fintech Legal Advisory in India
India's fintech regulation spans four financial regulators. Map yours before you launch.
2025
RBI Digital Lending Directions
2007
Payment & Settlement Systems Act
4
Financial Regulators
The Industry Landscape
India's fintech sector is regulated by multiple authorities simultaneously — RBI for payment systems, lending, and banking; SEBI for investment platforms, robo-advisory, and securities intermediaries; IRDAI for insurtech; and the PFRDA for retirement-focused products. A fintech startup that fails to identify its applicable regulatory framework early can build a product that is technically illegal, faces shut-down risk, or requires expensive structural changes before institutional investors will engage. Corpus Juris Legal advises fintech companies across the regulatory identification, licensing, and ongoing compliance spectrum.
- RBI payment aggregator (PA) licence application and compliance
- NBFC registration and regulatory compliance advisory
- SEBI investment adviser, research analyst and PMS registration
- Lending regulation — RBI Digital Lending Directions, 2025 compliance
- Account aggregator (AA) ecosystem legal advisory
- RBI sandbox application and regulatory testing framework
Frequently Asked Questions
Does a payment aggregator in India need an RBI licence?+
Yes. Payment aggregators (entities that facilitate payment collection between merchants and customers) must obtain authorisation from RBI under the Payment and Settlement Systems Act 2007. Existing PAs had to apply for authorisation by a specified deadline. New PAs must apply before commencing operations. Net worth requirements apply.
What is the RBI regulatory framework for digital lending?+
The Reserve Bank of India (Digital Lending) Directions, 2025 — which consolidated the 2022 guidelines — require: all loan disbursals and repayments to flow directly between the borrower and the regulated entity (no pass-through through LSPs), disclosure of the all-inclusive APR in a key fact statement, a cooling-off period, due diligence on lending service providers, and reporting of digital lending apps to the RBI. Third-party lending apps cannot collect repayments directly.
Can a foreign-funded fintech operate in regulated financial services in India?+
Yes, but FDI restrictions apply to certain regulated sectors — banking (74% cap), insurance (74% cap), multi-brand retail. For most fintech categories (payment aggregators, NBFCs, investment platforms), 100% FDI under the automatic route is permitted. However, regulatory approvals (RBI, SEBI, IRDAI) are required regardless of FDI compliance.
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