The issuer-readiness framework focuses on keeping credit records aligned across different facilities, payments, refunds, reversals, repayments and EMI conversions
BENGALURU, India, Aug. 26, 2026 /PRNewswire/ -- CARD91, a payments infrastructure company, today introduced its Credit Lifecycle Consistency Framework, a five-point industry framework designed to help banks assess their operational readiness for Credit Line on UPI (CLOU).

The framework focuses on ensuring that credit limits, outstanding balances and customer records remain accurate as payments move through refunds, reversals, repayments, EMI conversions and other lifecycle events.

The announcement comes as UPI enters its second decade. According to the Press Information Bureau, the network now connects 741 live banks and processed 2,365.8 crore transactions worth ₹29.87 lakh crore in July 2026. These figures represent the overall UPI network and demonstrate the operating scale within which UPI-based credit is developing.

The RBI's Fourth Amendment Directions on Credit Facilities, issued on June 23, 2026, clarified that the prudential treatment of UPI-linked credit must be determined by the nature of the underlying credit facility—not by the payment channel, instrument or technology used. The facility's terms must also form part of the bank's credit policy and comply with applicable regulations.

A successful UPI payment is only one event in a continuing credit relationship. Subsequent refunds, reversals, repayments or EMI conversions can alter the customer's available credit, outstanding dues and repayment schedule.

"Speed gets the customer through checkout, but consistency determines whether they trust the credit product," said Ajay Pandey, CEO, CARD91. "Each payment and subsequent credit event must receive the correct treatment for the underlying facility so that the bank and the customer continue to see the same financial position."
The Credit Lifecycle Consistency Framework
1. Apply facility-specific credit treatment
Interest-free, interest-bearing, fixed-term and revolving facilities may require different treatment of limits, repayments, refunds and outstanding balances.

2. Connect payment and credit records
UPI transactions and subsequent credit events should remain connected with the appropriate customer account. Refunds, reversals and repayments must update the relevant records accurately.

3. Align controls with bank policy
Transaction value, velocity and merchant-category controls—as well as portfolio actions such as limit changes and suspensions—should reflect the bank's credit policy and customer consent.

4. Reconcile repayments and EMI conversions
Repayments should be applied to the correct account, while EMI conversions should update the instalment schedule without duplicating the outstanding amount.

5. Maintain customer visibility and traceability
Available credit, outstanding dues and repayment obligations should remain consistent across applications, statements and alerts. Disputes, delayed reversals and manual corrections should follow a documented and reviewable process.

Lifecycle consistency means updating the appropriate credit records as each event is processed. The framework does not prescribe a universal processing timeframe or replace RBI requirements and individual bank credit policies.

For example, if a customer uses ₹10,000 from a ₹50,000 revolving credit line, the available credit would ordinarily fall to ₹40,000. Any subsequent refund, reversal, repayment or EMI conversion must update the relevant records according to the facility's terms. A fixed-term loan may require different treatment, reinforcing why payment processing cannot be separated from the underlying credit product.

Where CLOU is delivered through a digital-lending journey, the RBI Digital Lending Directions, 2025 may also apply to credit assessment, disclosures, servicing, repayment, grievance redressal and credit-information reporting.

CARD91's perspective is informed by its work on Nimbus, its Credit Line Management System. Nimbus supports different credit structures and connects credit lifecycle management with CARD91's NPCI-certified UPI 2.0 switch. Its publicly described capabilities include transaction and portfolio controls, consent management, EMI conversion, reconciliation and dispute resolution.

Technology should not determine lending policy or replace regulatory judgement. Its role is to help keep bank policy, transaction records and customer credit positions aligned.

As credit becomes an additional funding source on UPI, its next trust test will begin after the payment: whether every subsequent credit event leaves the bank and the customer with the same financial truth.

About CARD91
CARD91 is a payments and onboarding risk infrastructure provider, enabling regulated entities to launch and scale customer programs with ease. The platform supports seamless onboarding journeys, fraud detection, credit decisioning, card issuance across credit, prepaid, and forex, and UPI stack capabilities across issuance and acquiring.

Through its NPCI-certified capabilities and technology stack, CARD91 helps institutions design bespoke customer payment programs and market them with speed, security, and a seamless digital experience. Built by a team of bankers and technologists and proudly made in India, CARD91 operates across key financial hubs, including Mumbai, Bangalore, Delhi, and Chennai.

For more information, visit https://card91.io/ or contact [email protected].
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