Card91 introduces a five-point framework to help banks manage credit lines on India’s UPI network, ensuring compliance with RBI rules and fostering customer trust as UPI expands into a broader credit channel.
CARD91 has introduced a five-point framework it says is intended to help banks judge whether they are ready to offer Credit Line on UPI, or CLOU, as India’s UPI network grows into a larger credit channel. The company said the guidance is aimed at keeping credit limits, balances and customer records aligned as transactions move through refunds, reversals, repayments and EMI conversions. According to the Press Information Bureau, UPI connected 741 live banks and processed 2,365.8 crore transactions worth ₹29.87 lakh crore in July 2026.
The timing matters because regulators have begun to spell out how UPI-linked credit should be treated. The RBI’s Fourth Amendment Directions on Credit Facilities, issued on 23 June 2026, said the prudential treatment of such lending should depend on the nature of the underlying credit facility, not the payment rail or technology used. It also said the facility’s terms must be part of a bank’s credit policy and remain within applicable rules.
Ajay Pandey, chief executive of CARD91, said the user experience at checkout is only part of the story. “Speed gets the customer through checkout, but consistency determines whether they trust the credit product,” he said, adding that each payment and later credit event must be reflected correctly so that the bank and customer see the same position.
The framework sets out five practical steps: apply credit treatment based on the facility type; connect payment and credit records; align controls with bank policy; reconcile repayments and EMI conversions; and maintain visibility and traceability for customers. CARD91 said this means a revolving line, a fixed-term loan, an interest-free facility or an interest-bearing product may all need different handling, particularly when refunds or reversals change the outstanding amount. The company also said the approach does not replace RBI rules or impose a single processing timeline.
CARD91’s own Nimbus credit line management system underpins its view of the market. The company says Nimbus is built to support different credit structures and links credit lifecycle management with its NPCI-certified UPI 2.0 switch, with functions covering consent management, transaction and portfolio controls, EMI conversion, reconciliation and dispute resolution. The broader message is that technology alone cannot set lending policy; the harder test for CLOU is whether every later event after payment leaves both lender and borrower with a consistent financial record.
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