DPDP Act compliance

DPDP Act compliance for fintech, nbfcs and lending apps: what changes by May 2027

NBFCs, digital lenders, payment aggregators, wealth and insurance-tech platforms handle KYC documents, bank statements, credit scores, transaction data and device data. Here is what the DPDP Act means for you and what to fix first.

189 days to the DPDPA compliance deadline (13 May 2027)See the 2027 roadmap →
Quick answer

Fintechs, NBFCs and lending apps must comply with the DPDP Act by 13 May 2027 on top of RBI rules. KYC kept under anti-money-laundering law is a legal obligation (no consent needed), but marketing, cross-selling and app permissions need clear consent. Breaches must be reported to the Data Protection Board within 72 hours, alongside CERT-In (6 hours) and RBI reporting. Large lenders and payment firms are likely Significant Data Fiduciary candidates.

Deadline
13 May 2027
KYC retention
Legal obligation (PMLA)
Payment data
Stored only in India (RBI)
Breach reporting
Board 72 h · CERT-In 6 h

Where fintech, nbfcs and lending apps face the most DPDP risk

DPDP risk areas for fintech, nbfcs and lending apps
AreaWhat to do
App permissions (contacts, photos, location)Collect only what the loan needs, with consent; RBI digital lending rules already restrict this
Credit bureau pullsSpecific consent and purpose; keep consent logs
Recovery agents and partnersProcessor contracts; no misuse of borrowers' contacts
Cross-selling insurance and cardsSeparate opt-in for each product
Account aggregator dataUse within the consented purpose and duration

Other rules that apply alongside the DPDP Act

  • RBI digital lending rules (data minimisation, consent, storage in India)
  • RBI directive on storage of payment system data (2018): only in India
  • PMLA and RBI KYC directions on record retention
  • CERT-In Directions, 2022: 6-hour incident reporting and 180-day log retention

Where another law sets a stricter or longer requirement, follow both: the DPDP Act does not override sector rules on retention or storage.

Six steps to comply

  1. Map data across onboarding, KYC, underwriting, collections and partners.
  2. Align DPDP notices with RBI-mandated disclosures in the app.
  3. Separate legal-obligation data (KYC) from consent-based data (marketing).
  4. Merge DPDP, CERT-In and RBI incident reporting into one breach runbook.
  5. Review lending partners, collection agencies and LSPs as processors.
  6. Prepare for Significant Data Fiduciary duties if you are large.

Most DPDPA duties apply from 13 May 2027, with penalties up to ₹250 crore per breach. See the DPDPA 2027 roadmap and the DPDP compliance checklist.

Want it done for you? Our DPDP compliance service covers data mapping, notices, consent, vendor contracts, breach plans and staff training for fintechs, NBFCs, lending apps and payment companies.

Frequently asked questions

Does the DPDP Act apply to NBFCs regulated by RBI?

Yes. RBI regulation does not exempt NBFCs; the DPDP Act applies alongside RBI rules, and where another law requires something stricter (such as data storage in India), that law also applies.

Do fintechs need consent for KYC under DPDP?

Not where KYC is required by law: compliance with a legal obligation is a legitimate use under Section 7. Using KYC data for marketing or cross-selling needs consent.

DPDP guides for other industries

See all deadlines on the compliance calendar, or browse the compliance hub.

This guide is general information based on the law as of 25 October 2026, not legal advice. Rules and dates can change by notification; speak to a professional about your situation.

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