FLEXILOANS: THE BUSINESS OF PROMISING EASY CREDIT — AND THE UNCOMFORTABLE QUESTIONS BORROWERS ARE LEFT TO ASK

When a lender markets speed, convenience and transparency, borrowers are entitled to expect more than attractive loan advertisements, automated messages and a customer-support process that allegedly becomes difficult to access when something goes wrong.

FlexiLoans has built its business around a proposition that sounds almost irresistible to a small-business owner: access to business credit without the traditional banking ordeal. Faster applications, digital documentation, simplified underwriting, rapid decisions and convenient disbursals are central to the promise.

But there is another side to the digital lending experience that deserves considerably more attention.

A review of publicly accessible Google Play feedback, external consumer complaints, the company’s published lending policies, its privacy disclosures, its financial statements, credit-rating reports and available litigation records raises questions that cannot simply be dismissed as isolated customer dissatisfaction.

The questions are uncomfortable: Why do some applicants report receiving apparently positive loan communications before facing rejection? Why do borrowers allege that manual EMI payments were not reflected correctly? Why do some complainants describe repeated payment demands after claiming to have paid? Why are there complaints about inaccessible customer support, pending documents and difficulty deleting submitted information? How clearly are processing fees, bounce charges, late-payment charges and penal charges explained before a borrower accepts a loan? And what exactly does the company’s public data-safety disclosure mean when it states that data is not encrypted?

There is also a financial dimension. Epimoney’s asset-quality disclosures show that its on-book gross non-performing asset ratio deteriorated materially between FY2023 and FY2025 before improving in FY2026 and the first quarter of FY2027. The company’s credit-rating rationale continues to identify moderate asset quality, modest profitability and concentration in its funding profile as relevant considerations.

None of these facts, individually or collectively, establishes that FlexiLoans has committed fraud. But together they create a legitimate basis for demanding a much closer examination of how the business communicates with borrowers, administers repayments, handles personal information, imposes charges and resolves complaints.

The larger question is simple: when the business of lending is digital, who takes responsibility when the digital system fails the borrower?

A digital lending success story should not be measured only by downloads

The FlexiLoans application is listed on Google Play as a business-loan application associated with EPIMONEY PRIVATE LIMITED. Its public listing advertises more than one million downloads.

A third-party Google Play analytics snapshot dated 9 October 2026 recorded 24,281 ratings and an average rating of 4.58 out of five.

The distribution was:

The 1,842 one- and two-star ratings represent approximately 7.59% of the ratings in that snapshot.

That percentage should be read honestly. The majority of ratings were positive. A one-star rating is not proof of wrongdoing, and a rating does not necessarily contain a written complaint. It would be misleading to portray the entire user base as dissatisfied.

But the opposite conclusion would be equally convenient and equally misleading: that a high aggregate rating makes serious individual complaints irrelevant.

A lender dealing with business owners, bank statements, credit histories and repayment obligations cannot answer specific allegations merely by displaying an attractive average score. Digital reputation is not a substitute for accountability.

The written complaints matter because they identify particular areas of potential operational failure. They may not establish what happened in every individual case, but they tell the company, its regulator and prospective customers precisely what needs to be tested.

A necessary limitation about the review record

The publicly accessible review archive examined for this investigation exposed only a limited historical sample of written reviews. It did not provide the complete Google Play review corpus. Accordingly, the examples below are selected, publicly visible complaints, not a statistical representation of every FlexiLoans customer or every negative review ever submitted.

That distinction matters. Investigative journalism should expose unanswered questions, not manufacture certainty.

The approval that allegedly became a rejection: what exactly is the borrower being told?

Among the visible complaints are applicants who questioned the consistency of FlexiLoans‘ loan-approval communications.

A reviewer posting on 13 January 2025 alleged that the application process involved a credit-bureau check and that the applicant was initially informed that the loan had been approved, only to be told subsequently that it could not be approved.

Another reviewer, on 10 January 2025, claimed to have a CIBIL score of 780 and monthly income of approximately ₹1.70 lakh. The person said that an application for ₹2 lakh had been rejected, despite subsequently receiving a communication offering a loan of ₹5 lakh.

A separate applicant, posting on 14 January 2025, alleged that a loan was refused because of insufficient banking activity despite what the reviewer described as a good CIBIL score and an otherwise satisfactory repayment record.

These complaints do not prove that the company misrepresented approval status or improperly conducted credit assessments. A lender can legitimately change its decision after underwriting, verification, fraud screening, cash-flow analysis or a change in the applicant’s circumstances. A preliminary eligibility indication is not necessarily a final sanction.

But that is precisely the point.

There is a substantial difference between an eligibility estimate, a pre-approved offer, a conditional sanction and a final disbursal approval.

A borrower should not be left to guess which stage has actually been reached.

A digital lender should clearly disclose whether a message is merely promotional, whether the applicant has passed preliminary screening, whether credit verification is complete, whether a sanction has been issued and whether the disbursal remains conditional.

The company should also be able to produce its application-stage logs, communication templates, credit-bureau enquiry records, underwriting decisions and the precise reasons for a changed decision.

A message suggesting that approval has already been granted should not be used casually when the applicant is still awaiting fundamental underwriting checks.

The September 2026 communication controversy

A September 2026 Inventiva report reproduced two messages reportedly received by an applicant in connection with a proposed loan of ₹22,90,737.

The first message stated:

“Your loan has been pre-approved at 1% Interest and is ready for disbursal. Please review and complete your application…”

A subsequent message stated that the application was being reviewed and that pending details needed to be submitted to move ahead with verification.

The reported messages referred to the same application sequence and included a reference number.

If authentic and relating to the same application status, the two messages raise an obvious question: was the loan already ready for disbursal, or was the application still awaiting verification?

There may be an explanation. The first communication may have been conditional, automated, preliminary or generated from a different stage of the workflow. But if that is so, the explanation should be straightforward.

The company should publish a clear distinction between pre-approved, conditionally approved, sanctioned and ready-for-disbursal status. It should also explain the meaning of the advertised “1% Interest” in that particular message.

Its current public loan information describes interest rates starting at 12% annually, also expressed as 1% per month. That is a critical distinction. A statement of “1% interest” without the period or other relevant pricing information is not sufficiently precise for a borrower making a financial decision.

In lending, ambiguity is not a marketing achievement. It is a consumer-risk problem.

When the EMI is allegedly paid but the system still demands money

The complaints involving repayment administration are particularly important because they concern the part of the relationship where borrowers are financially exposed.

One reviewer posting on 20 September 2023 alleged that an EMI had been paid manually after an automatic debit problem, but the application continued to display an overdue amount.

Another reviewer, posting on 1 October 2023, claimed to have paid outstanding dues but continued receiving automated calls and WhatsApp messages demanding payment. That reviewer also complained of application problems, difficulties receiving OTPs and an ineffective customer-support experience.

A further review dated 30 August 2023 alleged repeated presentation of an EMI debit and additional bounce and late-payment charges. The reviewer cited an EMI of approximately ₹4,560 and claimed that repeated debit attempts every three days had pushed the total monthly outflow towards ₹11,000.

These are individual allegations. The underlying bank statements, mandate records, loan ledgers, debit instructions and payment confirmations have not been independently examined in this research.

Nevertheless, the operational questions are obvious.

When a borrower pays through an alternative channel after a failed mandate, how quickly is the payment reconciled? Does the collection system receive the updated status? Are automated reminders stopped immediately after verified payment? Can the borrower dispute an incorrect overdue entry without having to navigate a dysfunctional application?

A borrower should not be forced to prove the same payment repeatedly because a lender’s internal systems do not communicate with one another.

Nor should the lender’s technology problem become the customer’s financial liability.

If a payment has been received, the correct question is not how many automated reminders the system can generate. It is why the repayment ledger has not been updated and why collection communication has not been halted until reconciliation is complete.

A lending company should be able to provide a complete and intelligible account of:

• The original EMI due date.
• The date and time of every debit presentation.
• The date and time of every failed mandate.
• The date and time of any manual payment.
• The allocation of that payment.
• The date the loan ledger was updated.
• Every fee or penalty imposed, with the contractual and regulatory basis for it.
• The date on which collection communication was stopped.

If there is no discrepancy, the records should settle the matter. If there is a discrepancy, it should be corrected promptly.

A borrower’s repayment history should not be held hostage to an application screen.

Charges, penalties and the fine print: how much does the borrower actually pay?

FlexiLoans publicly advertises interest rates beginning at 12% per annum. Its Google Play listing states an APR range of 12% to 36%.

The company’s published fee information also sets out several charges, subject to the loan product and applicable terms.

The disclosed charges include:

Its published penal-charges policy also provides for penal charges on term loans of up to 36% per annum on overdue EMI amounts, calculated proportionately for the period of default, together with applicable GST.

These are published contractual or policy figures, not findings that the company has wrongly charged every borrower. Actual charges may vary according to the facility, sanction terms and applicable agreement.

But there is a substantive consumer-protection question here.

A loan advertised as convenient and transparent can still become expensive if the borrower does not understand the total cost of borrowing, the consequences of a missed payment, repeated debit attempts, foreclosure or other charges.

The company’s app itself gives an illustrative example of a ₹1 lakh loan for 12 months at 18% APR. It lists a ₹2,000 processing fee and ₹360 GST on that fee, interest of ₹10,016 and total repayment of ₹1,10,016, with total cost including the processing fee of ₹12,376.

That is useful disclosure. But a single illustration does not answer every borrower’s question.

The real test is whether each applicant receives an accurate Key Facts Statement before accepting the facility, with the actual APR, net disbursal, all applicable charges, repayment schedule and penal consequences clearly explained.

RBI’s penal-charge framework is not optional decoration

The RBI’s August 2023 instructions on penal charges make important distinctions.

Penal charges for non-compliance with material loan terms must not be used as a revenue-enhancement tool. They should be reasonable and commensurate with the relevant default or non-compliance. They must be disclosed in the loan agreement and applicable Key Facts Statement. Penal charges cannot simply be capitalised into the loan amount in a way that creates further interest on those charges.

The existence of a published 36% annual penal-charge ceiling does not, by itself, establish a violation. But neither does publication of a policy establish that every charge imposed in every account is lawful, proportionate or correctly calculated.

The question is how the policy operates in practice.

If a small business owner misses an EMI because of a short-lived banking or technical problem, what is the actual charge? Is it calculated only for the period of default? Is GST correctly applied? Are repeated debit presentations authorised? Are bounce charges limited to legitimate failed presentations? Is a borrower charged a late fee in addition to other charges for the same event, and, if so, is that permitted by the contract and applicable rules?

These questions can be answered through anonymised loan-ledger audits. There is no reason for the company to hide behind general statements about transparency.

A disclosed charge can still be disputed. A contractual clause does not place a lender beyond regulatory scrutiny.

The customer-support problem: a digital lender cannot outsource responsibility to an automated response

Some of the visible Google Play complaints describe technical failures and difficulties accessing assistance.

A reviewer on 5 February 2024 alleged that the app had been crashing for almost three months despite attempts to clear its cache and reinstall it.

A complaint dated 31 October 2023 alleged that uploaded bank statements had remained pending for two months, that the applicant had also emailed the documents, and that customer support had not resolved the issue. The applicant further claimed that the documents could not be deleted from the application.

The complaint is especially relevant because the documents involved were allegedly sensitive business and financial information.

A digital loan application may be convenient when everything works. But the service does not end when a borrower presses the submit button.

What happens when the application stops opening? What happens when an OTP does not arrive? What happens when a bank statement remains pending? What happens when a customer wants to withdraw from the application or remove information already uploaded? What happens when an incorrect overdue amount cannot be disputed because the application has become inaccessible?

These are not minor interface complaints. They concern the reliability of a financial service.

FlexiLoans publishes a grievance-redressal structure and specified escalation channels. The question is whether those mechanisms work in the cases where borrowers actually need them.

A lender cannot take the benefits of digital scale and then pretend that individual customer problems are too small to deserve human intervention.

A customer who is unable to resolve a repayment issue through the app should have a functioning telephone and written escalation channel. An applicant whose documents have been uploaded should know how to withdraw consent, request deletion where legally permissible and obtain confirmation of the action.

A grievance mechanism is not effective merely because a grievance email address exists on a website.

Data privacy: what exactly is being collected, and with whom is it being shared?

This investigation also raises questions about the handling and disclosure of personal information.

FlexiLoans’ published privacy policy describes the collection of information relevant to digital lending, including personal identity information, Aadhaar and PAN details, bank-account information, business financial information, credit-bureau information and other information used for underwriting and servicing.

It also describes the use of service providers, lending partners and other authorised parties in connection with the company’s operations.

That is not automatically unlawful. A regulated lender may need certain information to assess creditworthiness, disburse loans, comply with law, prevent fraud and service a facility. It may also use legitimate technology providers and lending-service partners.

However, the borrower must understand what information is being collected, why it is required, how long it is retained, which entities receive it and how consent can be withdrawn or deletion requested where permitted.

There is a further issue.

The Google Play Data Safety declaration displays the developer’s statement that the app does not share data with third parties, while the privacy policy describes disclosures to service providers, lending partners and other authorised parties.

Google’s Data Safety classification may treat certain service-provider processing or legally permitted disclosures differently from ordinary third-party sharing. Therefore, this apparent difference cannot, by itself, be labelled a breach or misrepresentation.

But it certainly warrants a plain-language explanation.

A customer should not need to compare platform declarations with a lengthy privacy policy to understand where sensitive financial information goes.

The encryption disclosure deserves an answer

The app’s Google Play Data Safety card also displays the declaration that “Data isn’t encrypted”.

That is a material disclosure for an application that handles sensitive identity, banking and business information.

The company’s website separately describes SSL encryption for website communications. These statements may concern different data channels or different security layers; they do not necessarily contradict one another. Nor does the Play Store declaration establish that a data breach has occurred.

But the question is too important to be ignored.

Does the declaration concern data in transit, data at rest, or a particular category of data? What encryption standards are used for identity documents and bank statements? Which information is accessible to service providers? How are access permissions controlled? What is the retention policy? What happens after a borrower withdraws an application? What security audits have been conducted?

If the declaration is accurate, the company should explain precisely what is not encrypted and why. If it is inaccurate or out of date, it should be corrected.

Data safety is not a decorative badge in an app store. For a digital lender, it is part of the essential trust relationship.

The borrower-calling controversy: an enquiry is not an invitation to endless solicitation

An external consumer complaint dated 26 October 2023, filed by a person identifying himself as Mehul Mehta, alleged that he had enquired about a business loan, subsequently decided not to proceed because of the charges and interest rate, and continued receiving approximately 20–30 calls per day despite communicating that he was not interested.

This is an allegation by an individual complainant, not an adjudicated finding against FlexiLoans.

Nevertheless, repeated commercial calls after a customer has clearly declined an offer deserve scrutiny.

India’s Telecom Commercial Communications Customer Preference framework regulates commercial communications, consent and promotional messaging. TRAI’s framework has also been amended, including amendments published in September 2026.

The company should be able to demonstrate that its promotional communications are based on valid consent and that requests to opt out are reflected in its systems. It should also distinguish genuine loan-servicing communications from sales and promotional communications.

A person enquiring about a loan does not thereby surrender the right to control subsequent marketing contact.

If the company believes the complaint is incorrect, the matter should be easy to resolve through call logs, consent records, campaign lists, telemarketer arrangements and opt-out timestamps.

The numbers behind the lending business: growth is impressive, but asset quality cannot be ignored

FlexiLoans is not a small, unknown application with no institutional footprint.

The FlexiLoans brand is associated with Epimoney Private Limited, a registered non-deposit-taking NBFC. Flexiloans Technologies Private Limited is a separate technology subsidiary. These entities should not be casually conflated, and allegations against one should not automatically be attributed to the other.

Acuité’s rating rationale dated 12 August 2026 reaffirmed Epimoney’s credit rating at A-/Stable for specified bank-loan and non-convertible debenture facilities and A2+ for its commercial-paper facility. The aggregate facilities discussed in that rationale amounted to ₹550 crore.

The same report showed substantial growth.

The rating rationale also identified modest profitability, moderate asset quality and concentration in the resource profile as relevant credit considerations. It reported that term loans and working-capital demand loans represented approximately 71% of the funding mix, with securitisation/Pass Through Certificates contributing approximately 26.6%.

The rating is a credit opinion, not a guarantee of customer satisfaction, a government certification of every lending practice or a declaration that the company has complied with every applicable consumer-protection requirement.

The asset-quality trajectory

One of the most relevant figures is the company’s on-book gross NPA ratio.

Acuité’s August 2026 report recorded the following trajectory:

The report also showed an on-book net NPA ratio of approximately 3.71% in FY2025 and 3.45% in FY2026.

The FY2023–24 annual report had recorded an on-book gross NPA ratio of 2.7% in FY2023 and 4.3% in FY2024, with net NPA increasing from 1.07% to 2.83%.

The progression matters.

The deterioration from FY2023 to FY2025 was significant. The subsequent improvement in FY2026 and Q1 FY2027 is also significant and should be acknowledged. It would be inaccurate to describe the company as experiencing uninterrupted deterioration when the latest disclosed figures show improvement.

However, improvement does not erase the earlier deterioration. Nor does it remove the need to understand the quality of the loan book, recoveries, write-offs, restructuring, underwriting standards and the distribution of borrower stress.

An NBFC can grow its AUM rapidly and still face difficult asset-quality questions. The two facts are not mutually exclusive.

The company and its rating analysts should be asked to explain what drove the FY2025 peak, which borrower segments contributed to stress, how recoveries improved the ratios and whether write-offs or portfolio transfers materially influenced the reported trend.

Growth figures make attractive investor presentations. Asset-quality figures reveal the more demanding side of the business.

The company’s own annual report: complaints were recorded, but what does the disclosure really tell us?

Epimoney’s FY2023–24 annual report recorded 219 complaints received during the year, against 585 in the preceding year.

It reported 243 complaints redressed during FY2023–24, including complaints carried forward from the opening balance, with no complaints pending at the close of the financial year.

The same report disclosed 19 maintainable complaints received through the Ombudsman mechanism during FY2023–24 and stated that all 19 were resolved in favour of the NBFC, with no amount awarded against it.

These disclosures must be included in any responsible analysis.

They do not support an allegation that every borrower complaint against the company was upheld or that the Ombudsman found against the lender. In fact, the company’s own reported Ombudsman outcome points in the opposite direction for those 19 matters.

But there is another important distinction: a complaint being received, a complaint being resolved internally, and a complaint being independently adjudicated are not interchangeable measures.

The company’s complaint numbers are useful, but they cannot independently establish that every borrower experienced a satisfactory resolution. Nor can online complaints automatically establish that the company’s records are wrong.

The right approach is to examine the underlying categories: loan rejection, fees, disbursal delays, payment reconciliation, collection calls, data privacy, application failures and grievance handling. The company should publish anonymised complaint trends, turnaround times, repeat complaints, reasons for closure and the number of cases reopened after an initial resolution.

A complaint counter is not enough. What matters is what the complaint was about, what evidence was examined and whether the borrower actually received a remedy.

A disclosure of fraud incidents must not be misrepresented

The FY2023–24 annual-report material reviewed also contains a fraud-disclosure table recording six instances with a total amount of approximately ₹25.4 lakh.

The disclosure does not, by itself, establish that Epimoney, its directors or employees committed fraud. The table does not identify the underlying actors or establish that the incidents involved wrongdoing by the lender against borrowers.

It would be irresponsible to convert a company-reported fraud disclosure into an accusation that the company itself committed fraud.

But the nature of those incidents, the recovery of approximately ₹11.7 lakh and the reported provisioning or write-off of approximately ₹10.2 lakh deserve proper classification and context in any full financial review.

The point is transparency, not insinuation.

Litigation records: thousands of cases associated with the lender, but most were filed by the lender itself

A company-record aggregation platform’s profile for Epimoney listed 7,855 court cases associated with the company in its November 2026 snapshot.

The same database classified:

The numbers are striking, but they need to be understood correctly.

The 7,855 figure does not mean 7,855 borrowers have accused Epimoney of misconduct. The database attributes 7,697 filings to Epimoney itself. The vast majority of the recorded docket is therefore associated with proceedings initiated by the lender.

The 158 cases categorised as filed against the company deserve case-by-case examination. The free database view does not establish the merits, facts, subject matter or outcome of every one of those matters. Nor should every case title containing Epimoney be assumed to concern a consumer grievance.

A court filing is not a finding of guilt. An interim order is not a final judgment. A recovery case is not a fraud conviction. And a borrower challenging a lender’s criminal complaint is not necessarily a case in which the lender has been found to have committed wrongdoing.

Nevertheless, a company with this volume of litigation should be able to provide an intelligible account of the main litigation categories, recovery actions, complaints against it and the status of material proceedings.

What two Calcutta High Court proceedings actually show

Two publicly accessible Calcutta High Court proceedings illustrate why the docket needs careful interpretation.

In Divya Srikar Venalakanti and Another v. Epimoney, CRR 546 of 2026, the petitioners sought to challenge criminal proceedings arising from a complaint by Epimoney. The underlying allegation by the lender concerned financing of approximately ₹11,56,884.16 and alleged non-repayment. The petitioners disputed the allegations, relying on repayment and arguing that there was no dishonest intention at the inception of the transaction.

The High Court admitted the matter and granted an interim stay of the complaint proceedings for the period specified in its order.

In Ankur Gupta v. Epimoney, CRR 4064 of 2025, the underlying complaint concerned an alleged loan of approximately ₹15 lakh to a proprietary business, with an outstanding amount stated to be approximately ₹12.09 lakh. The petitioner disputed his connection with the borrowing, asserting that he was the son of the deceased proprietor and was not responsible for the loan.

The High Court admitted the petition and stayed the proceedings for the period specified in its order.

These cases should not be presented as findings that Epimoney defrauded borrowers. In both matters, Epimoney was the complainant in the underlying proceedings, while the petitioners challenged the criminal process.

But the proceedings raise a legitimate question about how criminal allegations are initiated and pursued in commercial recovery disputes.

Where a lending company invokes criminal law, the distinction between a genuine offence and an ordinary repayment dispute must be carefully maintained. Equally, where borrowers challenge the company’s complaint, the court must be allowed to examine the evidence without prejudice or pressure.

The status of these proceedings after the interim orders should be checked against the latest court records before any further allegation is made.

The technology subsidiary is a separate legal entity

Flexiloans Technologies Private Limited is a separate company from Epimoney Private Limited. The company-record database also lists litigation associated with the technology subsidiary.

Those records should not be merged with the NBFC’s proceedings or casually used to attribute liability to the lending entity. The exact cause of action, parties, contractual role and current status of each matter must be verified from the underlying court record.

This is not a technicality. Corporate identity is fundamental to fair reporting.

MSME and supplier payment records also deserve scrutiny

The company-record database also displays four MSME Form 1-related records for Epimoney across the 2019–2023 period, referring to delayed payments to suppliers.

These are database-derived records rather than a complete, independently verified examination of the original filings and underlying invoices. They should therefore be treated as a lead for further verification, not as a final finding that the company unlawfully withheld payments.

Nevertheless, timely payment obligations matter. A business that lends to MSMEs should be expected to take its own supplier and contractual obligations seriously.

The company should clarify the nature, age and resolution of those records, supported by the original filings and payment evidence.

The RBI’s digital-lending framework: outsourcing does not outsource responsibility

FlexiLoans operates in a regulated lending environment. The responsibility for compliant lending does not disappear merely because applications, verification, collection or customer communication are performed through applications, vendors or lending-service providers.

The RBI’s Digital Lending Directions, 2025, place responsibility on the regulated entity for the conduct of its lending-service providers in the relevant digital-lending arrangement. They include requirements relating to due diligence, privacy, data protection, consent, appropriate data collection, loan disclosures and grievance redressal.

The framework also emphasises that borrower data should be collected on a need basis with appropriate consent and that regulated entities must maintain responsibility for the digital-lending arrangements they use.

For FlexiLoans, the practical questions are:

First, underwriting transparency: Is the borrower told whether the loan is at eligibility, verification, sanction or disbursal stage?

Second, credit-bureau transparency: Does the applicant know when a credit enquiry is being made, why it is necessary and how it relates to the loan application?

Third, repayment integrity: Can the company demonstrate accurate reconciliation between bank payments, mandate failures, EMI allocations and collection communications?

Fourth, data governance: Does the company retain clear consent logs, purpose limitations, deletion processes and records of disclosures to lending partners and service providers?

Fifth, grievance redressal: Can a borrower reach a responsible human officer when an application, repayment or collection system fails?

Sixth, service-provider oversight: Does the regulated entity regularly audit its outsourced service providers and the vendors that handle borrower data and customer communications?

The company cannot claim the convenience of digital outsourcing while disowning responsibility for the results.

A small but telling regulatory-information issue: is the borrower-facing redressal information current?

The RBI Integrated Ombudsman Scheme, 2026 became effective on 1 July 2026, replacing the 2021 scheme.

The regulatory information reviewed on FlexiLoans’ website continued to provide links carrying the earlier 2021 scheme title.

That may be a simple website-maintenance failure rather than a substantive violation. It does not establish that a customer was denied a remedy. But it is an avoidable problem on a website that is supposed to explain how borrowers can escalate grievances.

A lender’s grievance information should be accurate, current and easy to understand.

Borrowers should not have to work out which version of an Ombudsman scheme is currently applicable while trying to resolve an actual financial dispute.

The company should update the relevant links and clearly explain the current escalation mechanism, including the circumstances in which a complaint may be taken to the RBI’s complaint-management system.

A regulatory page should not be treated like an abandoned noticeboard.

The questions FlexiLoans should answer publicly

This investigation does not conclude that FlexiLoans has committed fraud, that its lending business is a scam, or that its executives have been found guilty of any criminal offence.

It does, however, identify specific questions that deserve clear answers from the lender and, where appropriate, regulatory examination.

The company should be asked to respond to the following:

1. How many applicants received messages describing their loans as approved, pre-approved or ready for disbursal before final underwriting and verification had been completed?
2. What controls prevent preliminary eligibility communications from being mistaken for final approval?
3. How many credit-bureau enquiries were conducted in FY2024–25, FY2025–26 and the first half of FY2026–27, and how does the company ensure that applicants receive appropriate disclosures and consent information?
4. How many repayment disputes involved a borrower claiming to have paid an EMI manually while the system continued to show an overdue amount?
5. How many complaints involved repeated debit presentation, bounce charges, late-payment charges or disputes over the allocation of repayments?
6. What is the average time taken to reconcile manual repayments and suspend automated collection messages after payment is verified?
7. How many applicants requested withdrawal of their loan applications or deletion of uploaded documents, and how many such requests were completed within the company’s disclosed timelines?
8. What is the precise meaning of the Google Play declaration that data is not encrypted, and what encryption standards protect identity information, bank statements and other sensitive records?
9. How does the company reconcile its Google Play Data Safety declaration with the privacy policy’s description of sharing with service providers, lending partners and other authorised entities?
10. What is the company’s process for ensuring that promotional calls and messages stop after a customer withdraws consent or opts out?
11. What proportion of the 158 cases classified by the company-record database as filed against Epimoney relate to borrower grievances, recovery disputes, contractual disputes or other matters?
12. What measures were taken after the increase in on-book gross NPA from FY2023 to FY2025, and what specifically drove the subsequent improvement?
13. What was the nature of the six fraud incidents reported in the FY2023–24 disclosure table, and how were the amounts classified, recovered, provided for or written off?
14. Has the company reviewed the accuracy and currency of its borrower-facing RBI Ombudsman information after the 2026 Scheme came into effect?
15. Will the company publish an anonymised annual complaint report identifying the nature of complaints, resolution times, repeat complaints, escalations and remedies provided?

These are not unreasonable questions. They are basic accountability questions for an NBFC serving businesses through a digital platform.

What regulators and enforcement authorities should examine

The answer is not to prejudge FlexiLoans or to demand punishment without evidence. It is to ensure that identifiable complaints and potential regulatory issues are examined promptly and independently.

RBI: a focused supervisory review

The RBI should consider examining the regulated lending entity’s borrower-communication processes, Key Facts Statements, penal-charge practices, repayment reconciliation, grievance mechanisms, digital-lending arrangements and oversight of service providers.

A targeted sample of borrower accounts could establish whether the charges shown in the loan agreements match the amounts actually collected.

The regulator should also examine whether the company’s digital systems record and preserve the consent, underwriting and repayment information necessary to resolve disputes.

TRAI: scrutiny of promotional contact and consent records

Where allegations concern repeated commercial calls or promotional messages, the appropriate examination should include consent records, telemarketer arrangements, registered headers, templates, complaint logs and opt-out timestamps.

The relevant evidence should determine whether applicable commercial-communication requirements were followed.

Credit-information companies: review disputed enquiry records

Where borrowers allege that credit enquiries were made without proper disclosure or that an enquiry adversely affected their credit profile, the original bureau records and enquiry purposes should be examined.

The actual effect on a credit score must be assessed from the credit-information record rather than assumed from a review comment.

Consumer and grievance authorities: effective redress

Where borrowers produce bank statements and transaction records showing payment despite continuing demands, the disputed accounts should be independently reconciled.

Consumers should receive a reasoned response and correction of any demonstrably inaccurate repayment status or charge.

Law-enforcement agencies: investigate only where evidence supports an offence

If documentary evidence indicates forgery, dishonest inducement, unauthorised use of personal information, unlawful threats or another cognisable offence, the competent authorities should investigate in accordance with law.

An ordinary loan default, a disagreement about charges or a technical failure should not automatically be labelled criminal fraud.

Equally, a genuine criminal allegation should not be dismissed merely because it arises from a commercial lending relationship.

Courts: timely adjudication without prejudice

Pending proceedings involving the company and its borrowers should be heard and disposed of in accordance with law and the evidence.

Where criminal proceedings are used in what may be an ordinary contractual or repayment dispute, courts should carefully examine the required legal ingredients. Where borrowers have engaged in genuine criminal conduct, that too should be established through due process.

Speed matters. So does fairness.

A delayed investigation or trial can punish both complainants and accused persons without a final decision. Faster, evidence-based proceedings are in everyone’s interest.

The larger question: can a digital lender demand trust without earning it?

FlexiLoans’ commercial proposition is built around speed and convenience. Its financial growth, institutional credit rating and substantial reported disbursals demonstrate that it has developed a significant lending operation.

But the larger a digital lender becomes, the greater its responsibility to maintain accurate records, clear communication, transparent pricing and responsive customer service.

A high Play Store rating cannot answer a borrower who says a payment was made but the system still shows overdue.

A published privacy policy cannot replace a clear explanation of encryption and third-party data access.

A sanction communication cannot be left so ambiguous that an applicant is unable to distinguish an indicative offer from final approval.

A fee schedule cannot replace a borrower-level calculation showing exactly why each charge was imposed.

And an automated collection system cannot be allowed to treat every unresolved data mismatch as an excuse to keep demanding money.

If the company has done everything correctly, it should welcome a transparent examination of the evidence. Bank statements, payment ledgers, consent records, application logs, credit-bureau enquiries, call records and sanction communications can resolve most of the questions raised here.

But if the systems are failing, the company should correct them. If disclosures are unclear, they should be rewritten. If charges have been wrongly levied, they should be reversed. If borrower data is mishandled, the responsible processes should be fixed. If complaints have not been properly examined, they should be reopened where justified.

A digital lending platform is not entitled to measure its success only by how quickly it can acquire applicants. It must also be judged by how fairly it treats them after they enter the system.

For a lender that promises to simplify business finance, the least it can do is ensure that a borrower does not need a second full-time job merely to understand an approval message, correct a repayment entry or obtain an answer from customer support.

The industry does not need another glossy promise of frictionless lending. It needs verifiable transparency, reliable repayment administration and meaningful grievance redressal.

FlexiLoans should answer the questions. The RBI and other competent authorities should examine matters within their jurisdiction where evidence warrants it. And any genuine dispute should receive a time-bound, impartial resolution.

The right to lend is accompanied by the responsibility to lend fairly.