P2P Lending Licence (NBFC-P2P) — RBI Registration for Peer-to-Peer Lending Platforms

Q: What is the minimum NOF for NBFC-P2P registration?

₹2 crore, one of the lower NOF requirements. The RBI also requires robust technology infrastructure, risk management, and experienced financial sector management.

Q: Can an NBFC-P2P guarantee returns to lenders?

No. The 2023 RBI directions explicitly prohibit return guarantees, credit enhancements, or any assurance to lenders. Credit risk must be fully borne by the lender.

Q: What are the exposure limits for lenders on P2P platforms?

Maximum ₹50 lakh aggregate across all P2P platforms for any lender or borrower; maximum ₹50,000 between any single lender-borrower pair across all platforms.

Q: Why does an NBFC-P2P need two separate escrow accounts?

Dual escrow ensures clean segregation: one account for lender funds before disbursement, another for borrower repayments before distribution. Both operated by a bank trustee. The platform never holds lender money directly.

Q: Can an NBFC-P2P cross-sell other financial products to its users?

No. The 2023 RBI directions prohibit cross-selling of any financial products — insurance, mutual funds, or credit cards — on P2P platforms.

Complete advisory for NBFC-P2P (Peer-to-Peer Lending) licence from the RBI — covering P2P platform registration, lender-borrower matching framework, escrow account compliance, exposure limits, technology requirements, and ongoing RBI reporting.

NBFC-P2P Registration

End-to-end advisory for NBFC-P2P registration with the RBI — minimum NOF of ₹2 crore, technology infrastructure assessment, business model review, application preparation, and COSMOS portal filing.

Escrow Account Structure

Advisory on structuring the mandatory escrow account arrangement for P2P platforms — two escrow accounts (lender funds and borrower funds) operated by a bank trustee, ensuring funds flow only between lenders and borrowers through the escrow.

Exposure Limit Compliance

Implementation of RBI's exposure limit framework — no lender to hold more than ₹50 lakh across all P2P platforms; no borrower aggregate exposure above ₹50 lakh; no single lender-borrower pair exposure above ₹50,000 — monitoring and enforcement controls.

Lender & Borrower KYC

Implementation of KYC and credit assessment framework — lender risk profiling, borrower credit assessment, mandatory disclosure of risk factors, and credit bureau integration for P2P lending compliance.

Platform Technology Compliance

Advisory on technology requirements for NBFC-P2P platforms — data localisation, IT security audit, algorithm-based matching transparency, credit scoring model disclosure, and RBI's technology outsourcing guidelines.

NBFC-P2P Annual Compliance

Management of all RBI periodic returns for NBFC-P2P entities, annual board review of risk management framework, and ongoing compliance monitoring — including exposure limit reporting and escrow reconciliation.

P2P Lending in India — Regulatory Landscape

Peer-to-peer lending platforms in India are regulated by the RBI as NBFC-P2P entities under the Master Directions for NBFC-P2P (2017), as amended. P2P platforms connect borrowers and lenders directly — eliminating the traditional banking intermediary — enabling higher returns for lenders and competitive rates for creditworthy borrowers. The RBI's regulatory framework strikes a balance between encouraging fintech innovation and protecting lenders from undue risk concentration.

In 2023, the RBI significantly tightened NBFC-P2P regulations — prohibiting platforms from offering credit enhancements or guarantees to lenders, barring cross-selling of credit products through the P2P platform, and mandating that funds always flow through the escrow mechanism with no cash movements outside. Non-compliance with the tightened framework has led to regulatory action against several P2P platforms.

Frequently Asked Questions

What is the minimum NOF for NBFC-P2P registration? +

The minimum Net Owned Fund for NBFC-P2P registration is ₹2 crore — one of the lower NOF requirements among NBFC categories, reflecting the intermediary nature of P2P platforms. However, the RBI requires NBFC-P2P applicants to demonstrate robust technology infrastructure, risk management capabilities, and an experienced management team with financial sector background.

Can an NBFC-P2P guarantee returns to lenders? +

No. The RBI's 2023 directions explicitly prohibit NBFC-P2P platforms from providing any assurance of returns, credit enhancements, or guarantees to lenders. Platforms cannot use provisions or reserves to compensate lenders for borrower defaults — the credit risk must be fully borne by the lender. P2P platforms that operated guaranteed return products were required to wind down such products following the 2023 RBI directions.

What are the exposure limits for lenders on P2P platforms? +

The RBI prescribes: (1) A lender's aggregate lending across all NBFC-P2P platforms cannot exceed ₹50 lakh; (2) A borrower's aggregate borrowing across all NBFC-P2P platforms cannot exceed ₹50 lakh; (3) Lending or borrowing by a single lender to a single borrower across all P2P platforms cannot exceed ₹50,000. NBFC-P2P platforms must implement systems to enforce these limits and verify cross-platform exposure through credit bureau checks.

Why does an NBFC-P2P need two separate escrow accounts? +

The RBI requires two separate escrow accounts to ensure clean segregation of lender funds and borrower repayments. The first escrow receives funds from lenders before disbursement to borrowers. The second receives repayments from borrowers before distribution to lenders. Both accounts are operated by a NBFC-P2P-designated bank trustee. The dual escrow structure prevents the P2P platform from commingling funds and ensures the platform never holds lender money in its own accounts.

Can an NBFC-P2P cross-sell other financial products to its users? +

No. The 2023 RBI directions prohibit NBFC-P2P platforms from cross-selling any financial products or services on their platform — including insurance, mutual funds, and credit cards. This prohibition was introduced to prevent P2P platforms from using their captive user base to generate fee income from cross-selling, and to ensure the platform focuses solely on its core function of matching lenders and borrowers.

Launch a Compliant P2P Lending Platform in India

NBFC-P2P registration, escrow structuring, exposure limit compliance, and technology framework advisory.

F.A.Q.

What is GSTR-9 and why is it required?

GSTR-9 is an annual GST return that summarizes all transactions reported during the financial year. It is required to ensure proper reconciliation and compliance with GST laws.

Who is required to file GSTR-9?

All regular GST-registered taxpayers are required to file GSTR-9, except composition dealers, casual taxable persons, and non-resident taxpayers.

What is the due date for filing GSTR-9?

The due date is generally 31st December following the end of the relevant financial year, unless extended by the government.

What details are included in GSTR-9?

It includes details of outward supplies, inward supplies, input tax credit claimed, taxes paid, and adjustments made during the year.

Is GSTR-9 mandatory for all taxpayers?

GSTR-9 is mandatory for most regular taxpayers, but certain small taxpayers may get exemptions based on turnover thresholds notified by the government.

What happens if GSTR-9 is not filed on time?

Late filing may result in penalties and late fees, along with potential compliance issues or notices from GST authorities.