Three years ago, most digital lending conversations in India started and ended with one question: “Kitni jaldi loan disburse ho sakta hai?” Speed was the entire pitch. Today, when we sit down with NBFCs, banks, and fintech founders at Speqto Technologies, the conversation looks completely different. Speed is now table stakes. What decision-makers actually ask about is compliance architecture, alternate data underwriting, and how to plug into the Account Aggregator ecosystem without rebuilding their entire tech stack.
This shift didn’t happen overnight, and it’s worth unpacking because it changes how BFSI leaders should be planning their tech roadmap for 2024 and beyond.
The RBI’s Digital Lending Guidelines (2022) were the real turning point. Overnight, practices that were common — like routing disbursements through third-party wallets, or letting Lending Service Providers (LSPs) collect data without clear consent flows — became compliance red flags. We worked with a mid-sized NBFC client last year that had to completely re-architect its loan origination system within four months because its existing LSP partnership model didn’t have a clean audit trail for borrower consent. That’s not a small UI fix; that’s a system-level rebuild involving consent management, key fact statements (KFS), and cooling-off period logic baked into the workflow itself.
What we’re seeing now is that lending platforms are being built compliance-first, not compliance-later. Digital lenders who treat RBI guidelines as an afterthought are the ones facing loan book freezes and reputational damage.
For a couple of years, Account Aggregator (AA) framework and OCEN (Open Credit Enablement Network) felt more like conference buzzwords than working infrastructure. That’s changed. We recently helped a fintech client integrate AA-based data pulls for underwriting salaried and self-employed borrowers, and the difference in turnaround time was significant — bank statement analysis that used to take a credit ops team 20-30 minutes of manual review now happens in under 90 seconds through automated parsing and consent-based data fetch.
More importantly, this isn’t just about speed. It’s about widening the addressable market. Borrowers with thin credit files — gig workers, first-time earners, small merchants — can now get assessed using cash flow data instead of relying purely on bureau scores. This is where a lot of the “financial inclusion” promise of digital lending is actually starting to show up in real portfolios, not just in pitch decks.
Two years ago, “alternate data” meant throwing SMS data, app usage patterns, and GPS location into a black-box model and hoping for the best. Regulators have since made it clear that opaque scoring models are a liability, not an asset. Lenders now need explainability — the ability to tell a borrower, and an auditor, why a particular score or decision was reached.
We’ve noticed our BFSI clients asking for underwriting engines that combine bureau data, GST returns, UPI transaction patterns, and utility payment history, but with a scorecard logic that’s documented and defensible. It’s a more mature approach than the “more data equals better model” mindset from a few years back.
Co-lending arrangements between banks and NBFCs have moved from pilot projects to core strategy for many lenders looking to scale without ballooning their own balance sheets. On the technology side, this demands real-time reconciliation between two (sometimes three) institutions, each with different risk appetites and reporting formats. We built a co-lending reconciliation dashboard for a client where the biggest technical challenge wasn’t the loan disbursement flow — it was making sure both partner institutions saw identical, real-time views of disbursed amounts, collections, and NPA classification without manual EOD batch jobs.
Embedded finance is the other big shift — lending is showing up inside e-commerce checkouts, B2B procurement platforms, and even payroll software, not just standalone lending apps. For BFSI players, this means your lending stack needs API-first architecture that a non-lending partner platform can integrate in weeks, not months.
At Speqto Technologies, we’ve built and re-architected lending platforms across these exact pressure points — consent-driven data flows, co-lending reconciliation, and alternate data scoring pipelines that hold up to audit scrutiny. The lenders pulling ahead right now aren’t necessarily the ones with the flashiest app. They’re the ones whose backend can handle a regulator’s question, a partner bank’s reconciliation request, and a borrower’s data request, all on the same day, without a scramble.
If you’re evaluating where your lending stack stands against these shifts, that’s a conversation worth having before your next audit cycle — not after.
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