The project undertook a systematic assessment of the monetary and non-monetary costs faced by Indian consumers using Buy Now, Pay Later (BNPL) products, a category of short-term digital credit that had grown rapidly without commensurate regulatory oversight.
The research methodology involved the usage of several BNPL products to reviews their terms and conditions, analyse product features, examine fee structures and implicit interest rates. Legal experts were also consulted to gauge applications’ compliance with existing consumer protection and credit regulations. This work culminated in the analytical report, “The Costs of Using Buy Now, Pay Later (BNPL) Products”. The report documented the true costs associated with BNPL credit, identified gaps in transparency and disclosure, highlighted risks arising from the then business models and weak grievance redress systems. It also offered recommendations for reform, including treating BNPL as regulated credit, mandating clear cost disclosures through Key Fact Statements, strengthening credit reporting, and establishing stronger consumer protection protocols.
Following dissemination, these findings were subsequently reflected in regulatory developments led by the Reserve Bank of India. After the publication of the report, the RBI’s Digital Lending Guidelines (2022, refined through FAQs and updated Directions in 2025) incorporated several of the report’s recommendations: BNPL was formally brought within the ambit of regulated credit when extended through banks and NBFCs; lenders were required to provide transparent, standardised disclosure of all fees; BNPL credit flows were mandated to be reported to credit bureaus; grievance redress and collections were strengthened; and the use of unregulated intermediaries for credit disbursal and repayment was curtailed.
