CARD91 Launches Five-Point Framework to Support Banks in Managing Credit Line on UPI

BENGALURU — Payments infrastructure company CARD91 has introduced a five-point Credit Lifecycle Consistency Framework designed to help banks assess their operational readiness for Credit Line on UPI (CLOU).

The announcement arrives as the UPI network enters its second decade of operation. According to data from the Press Information Bureau, the network currently connects 741 live banks and processed 2,365.8 crore transactions amounting to ₹29.87 lakh crore in July 2026.

The framework focuses on ensuring that credit limits, outstanding balances, and customer records remain accurate as payments move through various lifecycle events, including refunds, reversals, repayments, and EMI conversions. CARD91 noted that a successful UPI payment represents only one event in a continuing credit relationship, and subsequent actions can alter available credit and repayment schedules.

Ajay Pandey, CEO of CARD91, stated that consistency determines whether customers trust credit products. He emphasized that each payment and subsequent credit event must receive correct treatment so that both the bank and the customer maintain a unified view of the financial position.

The five-point framework outlines specific operational areas:

1. Apply facility-specific credit treatment: Different facilities, such as interest-free, interest-bearing, fixed-term, and revolving loans, may require distinct handling of limits, repayments, and outstanding balances.

2. Maintain continuous transaction mapping: UPI transactions and related credit events should stay connected with the correct customer account, ensuring refunds and repayments update relevant records accurately.

3. Enforce policy and control compliance: Transaction value, velocity, merchant-category controls, and portfolio actions like limit changes should reflect the bank's credit policy and customer consent.

4. Reconcile repayments and EMI conversions: Repayments must apply to the appropriate account, and EMI conversions should update instalment schedules without duplicating outstanding amounts.

5. Maintain customer visibility and traceability: Available credit, dues, and obligations should remain consistent across applications, statements, and alerts, with disputes and delayed reversals following a documented process.

The framework does not prescribe a universal processing timeframe or replace RBI guidelines and individual bank credit policies. It operates alongside existing regulations, including the RBI's Fourth Amendment Directions on Credit Facilities issued on June 23, 2026, which clarified that prudential treatment must be determined by the underlying credit facility rather than the payment channel.

CARD91's approach is informed by its work on Nimbus, its Credit Line Management System, which connects credit lifecycle management with its NPCI-certified UPI 2.0 switch. The company operates as a payments and onboarding risk infrastructure provider, supporting regulated entities with customer programs, fraud detection, credit decisioning, and card issuance.

"The expansion of credit on UPI represents a significant operational shift for the Indian banking sector. As transaction volumes scale rapidly, managing the backend lifecycle of credit—such as refunds, reversals, and EMI conversions—becomes critical for maintaining financial accuracy and customer trust. Frameworks that help institutions align transaction records with underlying credit policies will play an important role in supporting safe and sustainable digital lending growth." — Dr. Shishir Gupta, Founder & CEO, StartupLanes