5,658 CIBIL Complaints, Criminal Recovery Disputes and Rising Delinquencies: Epimoney’s FlexiLoans Faces a Tough Accountability Test

A financial institution that lends money to businesses has every legitimate right to recover its dues. Borrowers cannot simply walk away from their contractual obligations, and lenders are entitled to pursue lawful remedies when repayments are overdue.

But there is another side to the relationship: a lender cannot treat every repayment dispute as an invitation to deploy criminal proceedings, recovery agents, repeated communications or intrusive data practices without being prepared to explain exactly how those mechanisms are being used.

That is where Epimoney Private Limited, the company behind the FlexiLoans brand, faces uncomfortable questions.

A review of publicly available court orders, official credit-information disclosures, company filings, regulatory records and credit-rating reports reveals a record that deserves more than promotional assurances about convenient business loans.

It includes a historical Financial Intelligence Unit-India (FIU-IND) high-risk classification arising from a compliance lapse, thousands of credit-information complaints recorded by TransUnion CIBIL, several borrowers challenging criminal proceedings initiated by the lender, recovery-related representations reaching High Courts, and credit-rating disclosures documenting deterioration in certain delinquency indicators.

There are also important facts in the company’s favour: several complaints were recorded as resolved, Ombudsman complaints reported by the company were decided in its favour, its credit ratings were reaffirmed, and some asset-quality indicators improved during 2026.

Those facts do not erase the questions. Equally, the allegations do not establish criminal guilt.

The real issue is whether the lender’s customer-facing practices, credit reporting, recovery mechanisms and internal grievance systems are functioning with the transparency and accountability expected of an RBI-regulated financial institution.

And, more importantly, whether the regulator and law-enforcement authorities are examining the underlying records rather than waiting for borrowers to fight individual battles in court.

1. First, understand the company behind the FlexiLoans brand

FlexiLoans is not, in itself, the complete legal identity of the lending entity.

The company operating the platform is Epimoney Private Limited, CIN U71309TN1995PTC030536. The company was incorporated in 1995 under the former name Urmila Investment & Securities Private Limited and subsequently operated under the Epimoney name.

Its grievance-redressal disclosures identify FlexiLoans.com as a website owned by Epimoney Private Limited. The company describes itself as a non-deposit-taking, RBI-registered NBFC providing financial assistance, including to small and medium-sized businesses.

This distinction matters. Borrowers dealing with the FlexiLoans brand should be able to identify the regulated legal entity responsible for the loan, servicing, credit-information reporting, data handling and recovery process.

A digital brand may make borrowing look simple. Legal accountability, however, cannot be outsourced to a brand name or hidden behind an application interface.

A loan platform may be digital. Its regulatory obligations are not.

The company’s identity, incorporation details and ownership of the FlexiLoans website are reflected in its own regulatory and corporate disclosures. 【turn656793view1】【turn234789view8】

2. The CIBIL numbers: 5,658 complaints in FY2025–26

Perhaps the most important numerical disclosure in this investigation comes from TransUnion CIBIL’s own regulatory reporting.

CIBIL publishes institution-level information concerning credit records submitted by reporting institutions and complaints registered against them. Epimoney appears in those disclosures.

The figures are significant.

Financial year	Credit records submitted by Epimoney	Complaints recorded against Epimoney	Complaint rate	Unresolved beyond TAT
FY2023–24	2,87,929	201	0.070%	36
FY2024–25	9,74,809	4,320	0.443%	31
FY2025–26	13,12,249	5,658	0.431%	0

Source: TransUnion CIBIL’s published annual regulatory disclosures.

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The three-year total is 10,179 recorded complaints.

That number requires careful interpretation. It does not represent 10,179 independently verified victims or unique borrowers. CIBIL’s reporting methodology recognises that complaints, particularly those concerning personal information, may be referred to more than one credit institution. Its complaint figures must therefore not be represented as proof that every complaint was valid, upheld or attributable to deliberate misconduct.

Nevertheless, the scale and movement of the numbers deserve attention.

Between FY2023–24 and FY2025–26, the volume of credit records reported by Epimoney increased from approximately 2.88 lakh to 13.12 lakh. That is an expansion of more than four and a half times.

Yet the complaint rate reported by CIBIL also moved from 0.070% in FY2023–24 to 0.443% in FY2024–25 and remained at 0.431% in FY2025–26.

In other words, the increase cannot be explained merely by saying that the lender began reporting more records. The complaint incidence relative to records submitted was also materially higher than the FY2023–24 figure.

That is a legitimate subject for regulatory examination.

What were borrowers complaining about? Were disputes related to incorrect outstanding balances, delayed updates, repayment status, loan closures, personal information or other credit-reporting issues? How many complaints resulted in correction of data? How many were rejected, and on what grounds?

Those are precisely the questions that deserve a transparent, case-wise explanation.

There is, however, one favourable disclosure that must be recorded. In FY2025–26, CIBIL’s table showed zero complaints unresolved beyond the prescribed turnaround time at the relevant reporting reference date.

That is positive from a timeliness perspective. But resolving a complaint within the prescribed period and resolving it correctly are not necessarily the same thing. Regulators should examine the quality and outcome of resolutions, not merely the clock.

CIBIL itself describes a 30-day turnaround framework and explains the possibility of complaints being referred to multiple institutions. 【turn702721view0】【turn130475view0】

The question is not whether 5,658 complaints establish guilt. They do not. The question is why a lender with this scale of credit-information reporting generated this volume of complaints, what those complaints concerned, and whether the corrective action was adequate.

3. Borrowers challenge the use of criminal proceedings in loan-recovery disputes

One of the most consequential strands of the public record concerns criminal complaints initiated by Epimoney and subsequent challenges brought by borrowers before the Calcutta High Court.

These cases deserve particular attention because they raise an issue of considerable public importance: the distinction between a genuine criminal offence and an ordinary contractual or repayment dispute.

A borrower who defaults does not automatically become a criminal. Similarly, a lender’s legitimate right to recover a debt does not automatically validate every criminal allegation made in the process.

Whether a particular transaction involves cheating, criminal breach of trust or merely a civil repayment dispute depends on the evidence, the transaction’s circumstances and the applicable law.

Several borrowers have asked courts to examine precisely that distinction.

A. Reena Ravindra Khona and others: three separate criminal proceedings

In Reena Ravindra Khona and Another v. Epimoney, the Calcutta High Court dealt with three connected revision proceedings:

• CRR 5362 of 2025;
• CRR 5363 of 2025; and
• CRR 5364 of 2025.

These were separate proceedings arising from three distinct complaints:

High Court proceeding	Underlying criminal complaint
CRR 5362/2025	CS 81965/2022
CRR 5363/2025	CS 40001/2023
CRR 5364/2025	CS 64136/2023

The petitioners challenged the criminal proceedings and raised objections concerning the use of criminal-law provisions in what they contended were repayment disputes.

On 17 December 2025, the High Court found sufficient grounds to entertain the challenges and granted interim protection by staying the relevant proceedings for 12 weeks or until further orders, whichever was earlier.

A subsequent order dated 5 January 2026 corrected the loan amount referred to in the CRR 5364/2025 proceedings from ₹35 lakh to ₹25 lakh.

The distinction is important: the three criminal complaints were not simply duplicate versions of one proceeding.

The High Court’s interim intervention is relevant because the petitioners obtained judicial protection after raising arguable issues. However, an interim stay is not a final determination that Epimoney acted unlawfully or that the criminal complaints were fabricated.

Nor should it be represented as a permanent quashing of the proceedings.

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B. Ankur Gupta: a disputed question of responsibility for a business loan

In Ankur Gupta v. Epimoney, CRR 4064 of 2025, the Calcutta High Court examined another challenge to a criminal proceeding initiated in connection with a loan transaction.

The petitioner’s case was that the loan had been obtained by his deceased father’s sole proprietorship business and that he was not personally connected with the borrowing transaction in the manner alleged.

The matter concerned a loan of approximately ₹15 lakh, with the petitioner asserting that substantial repayments had already been made and disputing the alleged outstanding amount.

He questioned the basis for attributing criminal liability to him, including whether the necessary elements of entrustment or dishonest intention existed.

On 7 January 2026, the High Court admitted the revision petition and granted temporary protection by staying the underlying criminal proceeding for 12 weeks or until further orders.

The court’s action does not establish that Epimoney made a false complaint. It does, however, mean that the petitioner’s objections were serious enough to receive judicial consideration and interim protection.

The central issue remains one for the appropriate judicial determination: who was legally responsible for the borrowing, what evidence establishes that responsibility, and whether the allegations satisfy the legal requirements for a criminal prosecution?

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C. Divya Srikar Venalakanti: disputed dues of ₹11.56 lakh

Another matter, Divya Srikar Venalakanti and Another v. Epimoney, CRR 546 of 2026, concerned alleged outstanding dues of ₹11,56,884.16.

The lender’s criminal complaint alleged non-payment and dishonest conduct. The borrowers, on the other hand, argued that substantial repayments had already been made and that the circumstances did not establish dishonest intention from the inception of the transaction.

On 9 February 2026, the Calcutta High Court admitted the petition and granted interim protection by staying the underlying proceedings for 12 weeks or until further orders.

A subsequent order dated 17 April 2026 recorded that Epimoney was not represented at that hearing, that the petitioners were heard in part, and that the matter was listed for a further hearing.

That procedural development must not be exaggerated. Non-appearance at a hearing does not prove wrongdoing, and the interim order did not finally determine the dispute.

Nevertheless, the matter adds to the list of borrowers seeking High Court scrutiny of criminal proceedings arising from their loan relationships with Epimoney.

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What these proceedings collectively demand

The existence of these cases does not mean that borrowers are automatically right or that a lender cannot pursue criminal remedies where the law permits.

It means that courts have been asked to examine the legal basis of criminal proceedings in multiple separate loan disputes, and that interim judicial protection was granted in the proceedings described above.

A responsible lender should be able to demonstrate, with documentary precision, why a particular transaction is alleged to involve a criminal offence rather than a contractual default.

A criminal complaint is not a substitute for a recovery notice. A police process is not a collection agency. And a borrower should not have to face a criminal prosecution merely because a commercial transaction has gone wrong.

The distinction between a bad debt and a criminal offence is not a technical inconvenience. It is a basic safeguard of the rule of law.

4. Recovery-related allegations reach the Andhra Pradesh High Court

Another significant proceeding is M/s Yathi Traders v. State of Andhra Pradesh, Writ Petition No. 4231 of 2026, before the Andhra Pradesh High Court.

Epimoney was named as respondent number 6.

The petitioner alleged that the police had failed to act on a complaint dated 1 December 2025 concerning alleged high-handed recovery practices by multiple lenders and their agents.

It is essential to emphasise that the allegations in the case were directed collectively at several lenders and recovery agents. The petition did not establish a final finding of unlawful conduct by Epimoney individually.

On 23 February 2026, the High Court issued notice.

The proceedings took a further procedural turn on 5 May 2026. The High Court recorded that several respondents, including Epimoney, were absent despite an earlier direction concerning their appearance. The court then directed the Commissioner of Police, Visakhapatnam, to cause the specified respondents to be produced before it on 16 June 2026.

That direction should not be sensationalised as an arrest warrant. It was not a final finding of harassment, nor a judicial determination of criminal liability.

However, the proceeding is a substantive recovery-practices dispute in which Epimoney was specifically named.

The appropriate questions are straightforward:

• What was the nature of the complaint made to the police?
• What recovery practices were alleged?
• What response was submitted by each lender?
• What action did the police take?
• What was the subsequent status of the High Court proceedings?

A final substantive outcome after the June 2026 date was not located in the public records reviewed for this report.

The authorities should ensure that the underlying complaint is examined and that its status is made clear. A judicial direction should not disappear into procedural obscurity without a traceable outcome.

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5. A Madurai recovery dispute also reaches the High Court

In V. Chandran and C. Uma v. Superintendent of Police, CRL OP(MD) 9323 of 2026, the Madras High Court considered a petition seeking police protection.

The proceedings named several lenders and recovery-related respondents, including Epimoney/FlexiLoans and a recovery agent identified in the record.

On 7 May 2026, the High Court directed the police authorities to consider the petitioners’ representations within four weeks.

The order expressly did not decide the merits of the allegations.

It would be incorrect to claim that the High Court found Epimoney guilty of threatening or harassing the petitioners. No such final finding is contained in the order.

But the appearance of a lender and its recovery-related representatives in a police-protection proceeding is a matter that merits careful scrutiny.

When allegations involving recovery agents reach the High Court, the important exercise is not to declare guilt before investigation. It is to establish who contacted whom, under whose instructions, what was communicated, whether the agents were authorised, and whether any conduct crossed the boundaries prescribed by regulation.

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6. The Supreme Court record: proceedings must be read accurately

Two Supreme Court matters add further context to Epimoney’s recovery litigation.

A. Lemon Futermal Jain v. Epimoney

In Lemon Futermal Jain v. Epimoney, Transfer Petition (Criminal) No. 595 of 2022, the Supreme Court on 21 September 2022 issued notice and stayed proceedings in the specific criminal complaint case, CS/35490/22, titled Epimoney v. Tarun Polymers, before the Metropolitan Magistrate at Calcutta.

The short order did not make a finding that Epimoney had committed misconduct.

The judicial intervention should therefore be reported as an interim stay in a particular proceeding, not as a verdict against the company.

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B. Shalibhadra Traders v. Epimoney

In Shalibhadra Traders v. Epimoney, Transfer Petitions (Criminal) Nos. 452–453 of 2025, connected with Nos. 323–327 of 2025, the Supreme Court dealt with objections concerning the territorial jurisdiction of courts hearing seven complaints initiated by Epimoney.

The complaints involved two matters in Jaipur and five in Calcutta.

The petitioners sought to challenge the territorial jurisdiction and requested transfer-related relief.

On 25 July 2025, the Supreme Court directed the petitioners to raise their jurisdictional objections before the respective trial courts. It did not quash the complaints, transfer them to Mumbai, or declare that the original courts lacked jurisdiction.

The order also recorded Epimoney’s absence despite service at the relevant hearing.

This proceeding is important but should be understood correctly: Epimoney was the original complainant in those cases, and the Supreme Court’s direction concerned the forum in which the jurisdictional objections should be raised.

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Taken together, the Supreme Court record demonstrates that Epimoney has been involved in significant disputes concerning the prosecution and territorial jurisdiction of loan-related criminal complaints.

It does not, by itself, establish that the company abused the criminal process.

7. The 2018 FIU-IND high-risk classification: a historical compliance failure

The regulatory history goes back further than the recent litigation.

Epimoney’s name appeared at serial number 2317 in FIU-IND’s list dated 27 February 2018 of NBFCs categorised as high-risk financial institutions.

The reason stated in that list was non-registration of a Principal Officer under the Prevention of Money Laundering Act and associated rules.

This is a documented historical compliance issue.

But it must be reported accurately.

The entry did not establish that Epimoney had committed money laundering. It did not amount to a criminal conviction, and it should not be presented as proof of laundering funds or participation in a money-laundering network.

The distinction between a compliance failure and a money-laundering offence is fundamental.

There is also an important subsequent development: the exact name was not located in FIU-IND’s list dated 30 September 2026 of non-compliant NBFCs.

That later absence means the 2018 entry should not be described as a current blacklist classification. It does not, by itself, prove compliance with every other regulatory obligation.

The proper conclusion is that Epimoney has a documented historical FIU compliance issue, while the later list does not show the company under the same exact name.

A financial institution dealing with customer identities, financial data and lending transactions should be expected to maintain rigorous AML compliance. A historical lapse is therefore relevant to its compliance record, even though it cannot be converted into an allegation of money laundering.

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8. What Epimoney’s own annual report says about customer complaints

Epimoney’s FY2023–24 annual report provides a separate set of customer-grievance figures.

It reported:

• 219 customer complaints received during FY2023–24, compared with 585 in FY2022–23;
• 243 complaints disposed of during FY2023–24;
• no complaints pending at the end of FY2023–24; and
• 19 maintainable complaints received from the Office of the Ombudsman during FY2023–24, compared with 17 in the preceding year.

The annual report further stated that all 19 maintainable Ombudsman complaints in FY2023–24, and all 17 in FY2022–23, were resolved in favour of the NBFC. It disclosed no Ombudsman awards against the company in those figures.

These disclosures are favourable to Epimoney and should not be ignored.

However, they are not directly comparable with CIBIL’s institution-level complaints. They measure different complaint channels, different categories and different reporting processes. The numbers must not be added together or treated as proof of a contradiction.

The larger issue is that a lender’s grievance mechanism should be judged not only by the number of complaints it says it has disposed of, but also by the substance of the grievances, the evidence examined, the quality of redressal and the recurrence of problems.

A complaint marked disposed does not automatically establish that the customer received a satisfactory correction. Equally, a complaint against the company does not automatically establish that the customer was right.

A transparent institution should be willing to publish meaningful information about both.

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9. Credit quality: CRISIL recorded rising delinquency before later improvement

Another important dimension is the quality of the lender’s loan book.

CRISIL’s rating report dated 17 February 2026 recorded a deterioration in loans overdue by more than 90 days.

Reference period	Loans over 90 days past due	Adjusted for preceding 12-month write-offs
March 2024	2.7%	4.9%
March 2025	4.7%	8.0%
December 2025	4.8%	8.8%

The adjusted delinquency indicator increased from 4.9% to 8.8% over the reported period.

This is not a fraud finding. It is a credit-risk measure.

But it is an important measure for a lender whose business depends on collecting repayments from businesses that may themselves be exposed to changing economic conditions, liquidity pressures and cash-flow volatility.

CRISIL noted the risks associated with unsecured MSME lending and borrower cash-flow cyclicality. It also cited collection efficiency of approximately 101% over the relevant 12-month period, and reaffirmed the company’s BBB/Stable rating in February 2026. The amount of rated bank loan facilities was expanded from ₹100 crore to ₹200 crore.

The positive rating action and collection efficiency must be acknowledged. They do not make the earlier deterioration disappear.

The relevant question is whether underwriting standards, collection practices, loan restructuring, write-offs and risk management have improved sufficiently to prevent the deterioration from recurring.

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The August 2026 assessment: improvement, but not a clean bill of health

Acuité’s report dated 12 August 2026 reaffirmed:

• A-/Stable for the relevant long-term bank facilities;
• A-/Stable for the rated non-convertible debentures; and
• A2+ for the rated commercial paper.

Its report showed improvement in the company’s on-book gross NPA ratio:

Period	On-book gross NPA
FY2024–25	5.91%
FY2025–26	4.92%
Q1FY2026–27	4.17%

The same report showed on-book net NPAs of 3.71% in FY2024–25 and 3.45% in FY2025–26.

Acuité nevertheless continued to identify moderate asset quality, modest profitability and concentration in the borrowing profile among the factors constraining the rating.

For FY2025–26, the report recorded standalone total assets of approximately ₹2,307.24 crore, total income of ₹331.34 crore, and profit after tax of ₹17.89 crore.

These numbers show a lender with material operating scale, not a business whose financial condition can be casually described as insolvent or collapsed.

They also show why regulatory scrutiny matters: a company with a substantial loan book and a large customer base has a corresponding obligation to maintain effective controls over credit quality, recovery and grievance handling.

CRISIL’s delinquency figures and Acuité’s gross-NPA figures are different measurements and should not be mixed into a single series. The latter nevertheless indicates improvement in the more recent periods covered by that report.

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10. A securitised loan pool was put on Negative outlook in 2025

A further warning appeared in the securitisation market.

On 9 September 2025, India Ratings revised the outlook on Sudama 01 2025, an Epimoney-originated loan pool, from Stable to Negative.

The revision was linked to deterioration in delinquencies and lower collection efficiency in the relevant underlying pool.

In June 2026, the outlook was restored to Stable.

This needs careful explanation. The Negative outlook related to specific securitised instruments and the performance of their underlying loan pool. It was not a declaration that Epimoney had defaulted on all its obligations, nor was it a finding of corporate fraud.

Nevertheless, the episode demonstrates that the performance of at least one securitised pool had attracted rating-agency concern before the later restoration of the outlook.

It is another reason why the company’s collection performance, asset quality and reporting of credit risk deserve close monitoring.

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11. Debt-covenant disclosure and an impaired subsidiary investment

Epimoney’s FY2023–24 annual report also recorded that the company had exceeded an agreed debt-to-equity covenant threshold of 3 times following the transition from earlier accounting standards to Ind-AS.

The company explained that the accounting transition changed the relevant definitions and calculations. It stated that, under the previous accounting basis, it remained within the applicable limits; that it had informed the lenders in March 2024; and that it had sought the necessary relaxations.

It further stated that the lenders had taken no negative action.

This is the company’s explanation, and it should be presented as such. A covenant disclosure is not proof of fraud or deliberate financial misrepresentation.

But covenant breaches are not trivial accounting decorations either. They are matters that lenders and investors monitor because they can affect borrowing arrangements, financial flexibility and the cost of capital.

The same annual-report disclosures recorded a full impairment of the company’s ₹10.70 million investment—approximately ₹1.07 crore—in its wholly owned subsidiary, Flexiloans Technologies Private Limited. The subsidiary’s net worth was described as completely eroded.

This impairment concerned the subsidiary, not Epimoney’s own entire net worth. It should not be misrepresented as evidence that the parent company was insolvent.

Yet the disclosure is relevant to the group’s financial history and deserves to be understood in the context of its overall capital allocation and operating structure.

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12. Digital lending, personal information and the DND/NDNC clause

The other major area requiring scrutiny is personal-data handling.

Epimoney’s published privacy policy states that by clicking the acceptance checkbox, a user also authorises the company to contact them even where they are registered with the DND/NDNC registry.

The policy also describes the collection of information directly from users, through third parties and automatically through interaction with the company’s website and mobile application.

Separately, the policy describes the use of Gmail’s read-only permission, where the customer authorises access, to extract bank-statement information for a specified period. It states that this access is not intended to extend to other email messages.

These provisions do not establish that the company unlawfully accessed anybody’s data, misused an individual’s account or contacted a borrower without valid consent.

But they involve sensitive issues that deserve transparent explanation.

For example:

• How is consent obtained and recorded?
• How is consent withdrawn?
• What data is collected when an applicant does not proceed with a loan?
• How are third-party service providers monitored?
• What retention and deletion controls apply to submitted identity and financial documents?
• How does the company distinguish promotional communications from necessary loan-servicing communications?
• What safeguards prevent an applicant’s personal information from being used beyond the purpose for which it was provided?

The DND/NDNC provision, in particular, merits careful regulatory examination of the company’s actual consent and communication practices. A privacy-policy clause alone does not establish whether every contact made in an individual case was authorised under applicable telecom requirements.

In digital lending, the customer is not merely supplying a loan application. The customer may be disclosing identity records, banking information, financial behaviour and other highly sensitive information.

Consent cannot be treated as a magic phrase that makes every subsequent use of personal information automatically appropriate.

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13. Historical online complaints: warning signals, not judicial findings

Public consumer-complaint platforms also contain dated first-person allegations concerning FlexiLoans.

These complaints are not judicial findings. They have not been independently established merely because they appear on a website. They should be treated as unverified allegations and potential leads, not as proof of misconduct.

Nevertheless, the following examples are part of the publicly visible complaint history:

September 2018 — concerns over submitted identity documents

A user alleged that identity documents, including PAN and Aadhaar details, had been submitted after an advertised loan-processing proposition, but that communications from the platform did not follow. The user expressed concern about potential misuse of the documents.

The post did not establish that the documents were misused or that a data breach occurred.

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January 2021 — disputed ₹2,000 bounce-related amount

A user alleged that all 12 EMIs had been paid but that an additional ₹2,000 was demanded in connection with a purported cheque bounce.

The complaint-hosting platform subsequently marked the complaint as resolved on 20 January 2021. It does not, on its own, establish the precise nature of the resolution.

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October 2023 — allegation of repeated calls

A user posting on Consumer Complaints Court alleged that after making a business-loan enquiry and declining to proceed, the person continued receiving 20–30 calls a day despite asking for the calls to stop.

This remains an individual, unadjudicated allegation. No independent call records were available to establish the frequency or circumstances.

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January 2024 — allegation concerning personal-data collection and Aadhaar verification

A MouthShut reviewer alleged collection of personal information, unprofessional communications and Aadhaar verification without consent.

This is also an unverified user review. It is not an order of a consumer commission or a regulatory finding.

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These posts should not be inflated into a verified pattern of criminal conduct.

However, when older consumer complaints concern the same broad areas that later appear in court petitions or regulatory disclosures—recovery communications, identity information and credit-related disputes—it is reasonable for a regulator to examine whether any recurring systemic weaknesses exist.

The appropriate response is verification through transaction records, call logs, consent records and complaint files—not assumptions based on internet reviews.

14. What the public record does not establish

A critical investigative report must distinguish between what is documented and what is merely alleged.

The records reviewed for this article do not establish that:

1. Epimoney Private Limited has been convicted of fraud.
2. Epimoney has been judicially found guilty of money laundering.
3. The historical 2018 FIU listing was a finding of money laundering.
4. Every borrower complaint concerning Epimoney is genuine or has been upheld.
5. Every criminal complaint filed by Epimoney against a borrower was fabricated.
6. The High Courts in the recovery-related proceedings made final findings of harassment by Epimoney.
7. The company has suffered a confirmed data breach.
8. The company’s RBI registration has been cancelled.
9. A verified RBI monetary penalty, ED prosecution or CBI prosecution against Epimoney was established in the records reviewed.

The public-source review also did not authenticate every allegation appearing on third-party websites or every claim circulating in financial and corporate databases. Such claims should not be presented as fact without the underlying documents.

A historical press reference to business associations in the wider CG Power controversy also does not establish that Epimoney participated in the alleged CG Power fraud. That connection should not be used to imply criminal liability.

Likewise, an unverified aggregator reference to supplier-payment delays is not sufficient evidence of unlawful non-payment. It has therefore not been treated as an established finding in this report.

This distinction is not an attempt to soften criticism. It is what separates investigative journalism from a charge sheet written without evidence.

15. RBI cannot remain a spectator when the subject is recovery conduct

The Reserve Bank of India has already made its position on recovery agents clear.

In its 12 August 2022 circular on outsourcing of financial services and responsibilities of regulated entities employing recovery agents, RBI stated that the ultimate responsibility for outsourced activities remains with the regulated entity.

The circular also instructed regulated entities to ensure that neither they nor their agents resort to intimidation or harassment, whether verbal or physical. It identified practices such as public humiliation, intrusion into the privacy of family members, inappropriate messages, threatening or anonymous calls, persistent calling and calls before 8 a.m. or after 7 p.m. as prohibited conduct.

This is an important principle.

A lender cannot avoid regulatory responsibility merely by saying that a third-party agency or individual recovery agent made the call.

If an agent acts on behalf of a regulated lender, the lender’s supervisory and accountability obligations cannot be wished away through an outsourcing agreement.

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Epimoney’s own published grievance mechanism recognises that customer complaints may concern lending decisions, business practices, credit management, recovery and credit-information updates.

Its policy identifies a Grievance Redressal Officer, provides escalation to the Business Head if an issue is not resolved within 15 days, and identifies a route to the RBI if the grievance remains unresolved after 30 days.

That mechanism should be assessed by its actual performance, not merely by its existence on a website.

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16. What RBI, police and other authorities should do now

The purpose of regulatory scrutiny should be to establish facts, protect borrowers and ensure that legitimate lenders can recover genuine dues through lawful mechanisms.

It should not be to declare guilt in advance.

In light of the public record, the following actions deserve consideration.

A. RBI should examine credit-information complaints on a case-wise basis

The 5,658 complaints recorded in FY2025–26 warrant a structured review of their subject matter and outcomes.

The RBI should seek information on:

• The broad classification of the complaints;
• The number involving incorrect outstanding balances;
• The number involving repayment or loan-closure updates;
• The number resulting in corrections to credit records;
• The number rejected, along with the reasons;
• Repeat complaints involving the same underlying transaction; and
• Whether any systemic reporting or reconciliation issue exists.

The objective should be to distinguish genuine systemic weaknesses from routine or duplicate complaints.

B. Recovery-agent practices should be independently examined

Where credible complaints have been made, authorities should examine:

• Recovery-agent appointment and authorisation records;
• Background verification and training records;
• Call logs and available recordings;
• Borrower communications;
• Agency-wise complaint records;
• Internal disciplinary action, if any; and
• Instructions issued by Epimoney to its collection personnel and vendors.

The RBI’s rule that the regulated entity retains responsibility for outsourced recovery activities makes this examination particularly important.

C. Police should establish the factual status of the pending recovery-related representations

The representations and proceedings before the Andhra Pradesh and Madras High Courts should receive proper follow-through.

The relevant police authorities should establish what complaints were received, what evidence was supplied, whether any recovery agent was identified, what investigation was undertaken and what action was taken.

Where allegations are unsupported, the record should reflect that. Where evidence establishes unlawful conduct, the law should take its course without unnecessary delay.

D. Criminal proceedings should be examined promptly and fairly

The Calcutta High Court matters involving Reena Ravindra Khona, Ankur Gupta and Divya Srikar Venalakanti illustrate why the boundary between a civil loan dispute and a criminal offence must be carefully maintained.

Trial courts and investigating agencies should deal with such matters expeditiously.

They should examine the actual loan agreements, disbursement records, repayment histories, borrower identities, guarantor obligations and evidence of alleged dishonest intention.

Neither borrowers nor lenders should be allowed to manipulate legal processes. A genuine default should be recoverable through lawful means; a genuine criminal offence should not be shielded merely because the transaction originated as a loan.

E. Data and consent practices need a proper compliance review

The privacy policy’s DND/NDNC contact provision and its data-access provisions warrant examination against actual consent records, communication practices and data-handling controls.

The review should establish whether information is collected and retained only for appropriate, disclosed purposes and whether applicants can effectively withdraw consent where applicable.

F. Epimoney should publish more meaningful grievance information

The company should disclose, in a format that protects customer privacy:

• Annual complaint volumes by category;
• The number of complaints upheld or partly upheld;
• The number resulting in correction of credit information;
• The number involving collection agents;
• The number escalated to the Ombudsman or RBI;
• The number of repeat complaints; and
• The time taken to resolve complaints.

A company that believes its practices are fair should have little reason to fear meaningful transparency.

G. Enforcement must be faster, not arbitrary

Where evidence supports a regulatory violation or criminal offence, authorities should investigate and act promptly.

Where allegations are not supported by evidence, the parties concerned should not be subjected to indefinite suspicion.

The demand is for speedy investigation, reasoned decisions, timely trials and accountable enforcement, not for predetermined punishment.

17. The questions Epimoney must answer

Epimoney should be asked to provide a detailed response to the following questions before publication:

1. What were the principal categories of the 5,658 CIBIL complaints recorded against the company in FY2025–26?
2. How many resulted in corrections or changes to borrower credit information?
3. What internal analysis did the company undertake after the increase in complaint volumes during FY2024–25?
4. What were the facts behind the criminal complaints challenged in the Calcutta High Court proceedings?
5. What is the present procedural status of the Reena Khona, Ankur Gupta and Divya Srikar Venalakanti matters?
6. What was the company’s response in Yathi Traders and the Madras High Court police-protection matter?
7. What recovery agencies and agents were engaged during the relevant periods, and what controls were applied to them?
8. How does the company ensure compliance with RBI’s restrictions on intimidation, harassment and repeated recovery calls?
9. What is the company’s justification for the DND/NDNC contact clause in its privacy policy, and how is the required consent recorded?
10. What corrective steps have been implemented in response to the historical FIU compliance issue?
11. What explains the deterioration in the CRISIL-reported 90-plus-day delinquency indicators through December 2025?
12. What measures contributed to the subsequent improvement reported by Acuité in 2026?

The company’s reply should be published in full or fairly summarised, with supporting documents where appropriate.

Conclusion: A lending business needs more than disbursals and recovery numbers

Epimoney operates in a sector that serves businesses requiring access to credit. Such lending can be economically valuable, particularly for smaller enterprises that struggle to obtain traditional bank finance.

But the value of lending cannot be judged only by the speed of loan approvals, the size of the disbursal book or the ability to recover overdue money.

It must also be judged by the accuracy of credit reporting, the fairness of recovery practices, the treatment of borrowers, the security of personal information and the lender’s willingness to submit its conduct to scrutiny.

Epimoney’s public record presents a mixture of facts that should not be hidden behind either exaggerated accusations or corporate assurances.

The 2018 FIU entry was a documented historical compliance lapse, not a money-laundering conviction. CIBIL recorded 5,658 complaints against the company in FY2025–26, while also recording that none remained unresolved beyond the prescribed turnaround time at the reporting reference date. Multiple borrowers obtained interim judicial protection while challenging criminal proceedings. Recovery-related allegations reached the Andhra Pradesh and Madras High Courts without producing, in the orders reviewed, final findings of misconduct against Epimoney. Credit-rating reports recorded deterioration in some delinquency measures and subsequent improvement in others. The company’s own disclosures also record complaints disposed of and Ombudsman outcomes favourable to the NBFC.

That is not a conviction sheet.

It is, however, a substantial public record that calls for answers.

The company should not be condemned on the basis of allegations alone. But neither should thousands of credit-information complaints, repeated courtroom disputes and recovery-related representations be dismissed as inconvenient noise.

The proper response is independent examination, transparency and timely adjudication.

A lender that expects borrowers to answer for every rupee should be equally prepared to answer for every complaint, every disputed credit entry, every recovery communication and every legal proceeding.

That is not hostility towards the lending industry. It is the minimum standard of accountability expected from a regulated financial institution.

And if the evidence establishes misconduct, the response should not be another round of procedural delay. It should be prompt regulatory and legal action under the applicable law.