Who the guidelines apply to
The RBI Digital Lending Guidelines (originally 2022, updated in subsequent circulars) cover every Regulated Entity (RE) that lends digitally and every Lending Service Provider (LSP) that sources, services or collects on their behalf. A retail store offering EMI at the counter is an LSP touchpoint the moment it captures customer data for a loan.
The 9-point merchant checklist
Before onboarding your first customer on ZepCart, confirm every item below is either handled by the platform or actioned by your staff.
- Display the lender's name on every quote, receipt and communication — never your own store name as the lender
- Share the Key Fact Statement (KFS) before disbursal, in a language the customer understands
- Disclose the Annual Percentage Rate (APR), processing fee, GST and any recovery charges up front
- Honour the cooling-off / look-up period — customers can exit within the window without penalty (beyond APR)
- Route customer data only through the RE or approved LSP APIs; no local storage on shop devices
- Publish a grievance officer name, phone and email visible at the store and inside the customer app
- Maintain digital consent artefacts for KYC, credit pull and data sharing — timestamped and retrievable
- Segregate merchant, customer and lender flows in your books; reconcile settlements weekly
- Complete annual staff refresher on fair-practice code, recovery conduct and DPDP obligations
What ZepCart handles automatically
The merchant portal was built to make compliance the default, not an afterthought. Every EMI lead automatically generates a lender-branded KFS PDF, captures Aadhaar-eSign consent, records the cooling-off timestamp and files a tamper-evident audit trail in the document vault.
- KFS auto-generated and shared with the customer over email + SMS
- Aadhaar eSign via Signyu — legally valid under IT Act, 2000 §5
- Grievance officer contact injected into every customer receipt
- Row-Level Security so no merchant can see another merchant's leads
- Encrypted document vault with signed-URL access and 7-year retention
DPDP Act, 2023 — what changes for retailers
The Digital Personal Data Protection Act came into force with phased notifications. For a merchant, three obligations matter most: purpose limitation (collect only what the loan needs), notice + consent (in plain language), and breach reporting to the Data Protection Board within stipulated timelines. ZepCart's consent capture screens are pre-built to satisfy all three.
What happens if you skip the checklist
Non-compliance is not just a lender-side risk. RBI can direct the RE to suspend the LSP relationship, which means your store loses EMI access overnight. DPDP penalties for data misuse can reach ₹250 crore for the responsible entity. The good news: a merchant on ZepCart inherits compliance-by-design; the checklist above becomes a monthly verification, not a build project.
Frequently asked questions
Do I need a separate NBFC licence to offer EMI in my store?
No. As long as the loan is booked by an RBI-regulated bank or NBFC (our finance partners), you operate as a Lending Service Provider touchpoint. You must, however, follow the LSP obligations described above.
Is the Key Fact Statement mandatory for small-ticket EMI?
Yes. The RBI requires a standardised KFS for every digital loan regardless of ticket size. ZepCart auto-generates and shares it before disbursal.
How long is the cooling-off period?
The look-up / cooling-off window is defined by the lender in the KFS, typically 3 days for personal-loan style products. Customers can exit by returning the disbursed amount plus APR for the used days.
Where is the grievance officer information shown?
On the KFS, on the sanction letter, in the customer email and inside the ZepCart merchant receipt printed at the counter.
Does ZepCart store Aadhaar numbers?
We store only the masked Aadhaar reference token returned by the eSign service, never the full 12-digit number, in line with UIDAI and DPDP guidance.
Want ZepCart at your store?
ZepCart onboards merchants by invitation. Talk to our team to activate no‑cost EMI, EV finance and consumer‑durable loans at your counter.
Request an invitation