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RBI tightened NBFC-P2P regulation substantially in August 2024 — escrow structure, lender exposure caps, and marketing language all changed. CS Chetna Shoor personally reviews your NOF, platform readiness, and fund-flow structure against the current rules before filing.
NBFC-P2P is the RBI license for online marketplaces that match individual lenders with individual borrowers — the platform itself is an intermediary, not a lender on its own balance sheet. That structure means RBI’s review goes beyond the standard NBFC documentation set: your escrow arrangement, fund-flow mechanics, and matching policy all need to work exactly as the Master Directions require, not just be described correctly on paper.
This page is for founders building a P2P lending marketplace from the ground up. Chetna reviews your Net Owned Fund structuring, escrow and trustee arrangement, and board-approved policies — matching, pricing, fund transfer — against RBI’s August 2024 amendments before any of it goes to RBI.
Minimum Net Owned Fund for NBFC-P2P registration
Aggregate exposure cap per lender across all P2P platforms (revised Aug 2024)
Aggregate loan cap per borrower across all P2P platforms
Maximum maturity permitted for a P2P loan
Maximum time funds may sit in escrow before transfer
Legal basis: RBI Act, 1934 plus the NBFC-P2P Master Directions, as amended August 2024
RBI rejects over 40% of NBFC applications on the first attempt. Here’s what actually causes it.
Because NBFC-P2P is a technology-driven intermediary model, RBI's review typically extends to whether your matching engine, KYC flow, and escrow integration actually function as described — not just whether the business plan says they will. Applicants who file before their platform is functionally ready tend to draw follow-up queries that a completed application wouldn't.
The August 2024 amendments require two separate escrow accounts — one for lender funds, one for borrower repayments — operated through a bank-appointed trustee, with funds transferred within one business day (T+1) of receipt. Platforms that co-mingle these accounts or let funds sit past T+1 are a common source of supervisory findings, not just registration-stage queries.
RBI explicitly prohibits presenting P2P lending as an investment product, and prohibits any credit enhancement or guarantee that would make it feel like one. Platforms whose app copy, return projections, or promotional material blur the line between "peer-to-peer loan" and "investment return" face regulatory pushback regardless of how the legal loan structure is drafted.
NBFC-P2P fits a specific business model — a pure marketplace connecting individual lenders and borrowers, without lending from your own balance sheet. It’s worth confirming that’s actually your model before filing.
The default category for most lending and investment businesses — covers a broad range of financial activity under one license. Most new applicants fall here.
For microfinance-focused lenders. Carries a lower NOF threshold of ₹5 crore instead of ₹10 crore — often the better fit for early-stage microfinance promoters.
For groups that primarily hold shares and investments in other group companies rather than lend to the public — a distinct, lighter-touch regulatory category.
We confirm your NOF position, whether your platform model fits NBFC-P2P specifically, and your promoters' fit-and-proper standing.
A full review of what you have against what RBI expects for a P2P filing — including the escrow structure and matching policy most generic NBFC checklists miss.
Chetna reviews the business plan, escrow/trustee arrangement, and matching and pricing policies before they're finalized.
Submission through the COSMOS portal, followed by physical document submission to the RBI regional office.
We respond to every RBI query directly, including any follow-up on platform functionality or fund-flow mechanics.
Once the Certificate of Registration is issued, we set up escrow monitoring, disclosure protocols, and your statutory registers alongside the RBI returns calendar.
Fund-flow and disclosure obligations don’t stop at the Certificate of Registration — they apply to every transaction that moves through your platform.
Public disclosure of portfolio performance, non-performing assets, and lender losses. See NBFC Annual RBI Compliance.
Companies Act filings continue in parallel with RBI obligations.
Ongoing customer due diligence and borrower-consent protocols before identity disclosure to lenders.
Maintaining the T+1 settlement discipline and segregated lender/borrower escrow accounts on an ongoing basis.
CS Chetna Shoor’s team replies within 4 hours on WhatsApp.
NBFC-P2P platforms need a minimum Net Owned Fund of ₹2 crore under Section 45-IA of the RBI Act, 1934 — lower than most NBFC categories, since a compliant P2P platform is a pure intermediary and doesn’t carry lending risk on its own balance sheet. This threshold has stayed at ₹2 crore even as RBI raised the NOF requirement for categories like NBFC-ICC to ₹10 crore.
Under RBI’s August 2024 amendments, a lender’s aggregate exposure across all P2P platforms is capped at ₹50 lakh, and a borrower’s aggregate loans across all platforms are capped at ₹50 lakh as well. Lenders investing more than ₹10 lakh across platforms must provide a chartered accountant’s certificate confirming a minimum net worth of ₹50 lakh, and individual P2P loans cannot exceed a 36-month maturity.
NBFC-P2P platforms must maintain two separate escrow accounts — one for funds received from lenders and one for borrower repayments — operated through a trustee appointed by a scheduled commercial bank. Funds cannot remain in either escrow account for more than one business day (T+1) from receipt, and platforms are barred from using a lender’s funds for any purpose other than disbursement to matched borrowers.
Most NBFC-P2P applications take 3–6 months from filing to Certificate of Registration, similar to standard NBFC timelines, provided the business plan, escrow structure, and required board policies are complete on first submission. Because RBI’s review often extends to whether the platform itself functions as described, applications filed before the technology is genuinely ready tend to draw queries that extend this timeline.
Once registered, an NBFC-P2P must publicly disclose portfolio performance and lender losses, maintain the segregated escrow structure with T+1 settlement, obtain borrower consent before sharing identity with lenders, and continue standard NBFC obligations like NBS returns and KYC/AML compliance. See our NBFC Annual RBI Compliance service for ongoing filing support.
Qualified Company Secretary · ICSI Member · Founder, Expertvuw Management Pvt Ltd
Chetna has guided NBFC promoters through RBI’s COR process end to end, with particular focus on structuring the Net Owned Fund and business plan so the application survives first-round RBI scrutiny rather than coming back with a query.