CARD91 Introduces Five‑Point Credit Lifecycle Consistency Framework for UPI Credit Lines
CARD91, a payments infrastructure provider, announced the Credit Lifecycle Consistency Framework, a five‑point industry model designed to help banks assess their operational readiness for Credit Line on UPI (CLOU). The framework targets the accurate alignment of credit limits, outstanding balances and customer records as transactions progress through payments, refunds, reversals, repayments and EMI conversions.
The announcement references the scale of the UPI ecosystem, noting that, according to the Press Information Bureau, the network connects 741 live banks and processed 2,365.8 crore transactions worth ₹29.87 lakh crore in July 2026. This operating magnitude underscores the environment in which UPI‑based credit products are emerging.
RBI’s Fourth Amendment Directions on Credit Facilities, issued on 23 June 2026, clarified that prudential treatment must be determined by the nature of the underlying credit facility rather than the payment channel, instrument or technology. Consequently, the terms of each facility must be incorporated into the bank’s credit policy and comply with applicable regulations. The framework does not replace RBI requirements but provides a structured approach for banks to maintain consistency.
The five points are:
1. Apply facility‑specific credit treatment – Differentiate handling for interest‑free, interest‑bearing, fixed‑term and revolving facilities.
2. Connect payment and credit records – Ensure UPI transactions and subsequent credit events remain linked to the appropriate customer account, with refunds, reversals and repayments updating records accurately.
3. Align controls with bank policy – Transaction value, velocity and merchant‑category controls, as well as portfolio actions such as limit changes and suspensions, must reflect the bank’s credit policy and customer consent.
4. Reconcile repayments and EMI conversions – Repayments should be posted to the correct account, and EMI conversions must adjust the instalment schedule without duplicating the outstanding amount.
5. Maintain customer visibility and traceability – Available credit, dues and repayment obligations should be consistent across applications, statements and alerts, with disputes and manual corrections following a documented, reviewable process.
An illustrative example states that if a customer draws ₹10,000 from a ₹50,000 revolving credit line, the available credit falls to ₹40,000; any subsequent refund, reversal, repayment or EMI conversion must update the records according to the facility’s terms. Fixed‑term loans may require different treatment, reinforcing that payment processing cannot be separated from the underlying credit product.
Where CLOU is delivered through a digital‑lending journey, the RBI Digital Lending Directions 2025 may also apply, covering credit assessment, disclosures, servicing, repayment, grievance redressal and credit‑information reporting.
CARD91’s perspective is informed by its Nimbus Credit Line Management System, which supports various credit structures and links credit‑lifecycle management with CARD91’s NPCI‑certified UPI 2.0 switch. Nimbus capabilities include transaction and portfolio controls, consent management, EMI conversion, reconciliation and dispute resolution. The company emphasizes that technology should not dictate lending policy or replace regulatory judgement; instead, it should help keep bank policy, transaction records and customer credit positions aligned.
Ajay Pandey, CEO of CARD91, stated, “Speed gets the customer through checkout, but consistency determines whether they trust the credit product. Each payment and subsequent credit event must receive the correct treatment for the underlying facility so that the bank and the customer continue to see the same financial position.”
About CARD91
CARD91 provides payments and onboarding risk infrastructure, enabling regulated entities to launch and scale customer programs. Its platform offers seamless onboarding, fraud detection, credit decisioning, card issuance across credit, prepaid and forex, and UPI stack capabilities across issuance and acquiring. Operating from Mumbai, Bangalore, Delhi and Chennai, CARD91 leverages NPCI‑certified technology to help institutions design bespoke payment programs with speed, security and a seamless digital experience.