NBFC GUIDE · CO-LENDING

Co-lending reconciliation under RBI’s 2025 directions

What the Co-Lending Arrangements Directions, 2025 require, and the month-end reconciliation that keeps an NBFC’s books, its partner’s books and the borrower’s record in agreement, including Business Correspondent partners.

By Regi Tom Antony, FCA, MBA (Australia), ACMA (UK), CGMA (USA), CISA (USA) · Former Group CFO/COO (OSRAM/Siemens, Westcon Group) · Published 4 November 2026

IN SHORT

Under the Reserve Bank of India (Co-Lending Arrangements) Directions, 2025, which apply from 1 January 2026, each co-lending partner must retain at least 10% of every loan, the originating lender may give a default loss guarantee of up to 5% of outstanding loans, and partners must share any change in a loan’s SMA or NPA status by the next working day. Co-lending reconciliation checks that each partner’s share of principal, interest, charges, escrow flows, servicing fees and guarantee, and the loan’s asset classification, agree in both lenders’ books.

01 · THE RULES

What the 2025 co-lending directions require

AREAREQUIREMENT
Effective date1 January 2026, with early adoption permitted
Minimum retentionEach partner holds at least 10% of each loan (the earlier priority sector framework required 20%)
Default loss guaranteeOriginating lender may provide up to 5% of outstanding loans
Asset classificationChange in SMA or NPA status shared with the partner by the next working day
Credit bureausEach lender reports its share to credit information companies
Customer interfaceA single point of customer interface identified, with a Key Facts Statement
DisclosureActive co-lending partners listed on the lender’s website; quarterly or annual disclosures in financial statements
KYCPartner lenders may rely on the originating lender’s KYC
02 · WHERE IT BREAKS

Why co-lending books drift apart

  • Collections are split between partners in a different order (fees first, interest first) from the agreement.
  • Prepayments and foreclosures are processed in one lender’s system before the other’s.
  • Interest is computed on different day-count or rate-reset conventions.
  • Servicing fees and guarantee invocations are booked late or at summary level.
  • A loan is marked SMA or NPA in one lender’s books but not the other’s.

Each break is small, but over thousands of loans it shows up in returns, credit bureau data, provisioning and the auditor’s questions.

03 · MONTH-END

A monthly co-lending reconciliation routine

  1. Match the partner’s portfolio tape to your loan system, loan by loan: principal outstanding, interest accrued, charges, overdue days.
  2. Recompute each partner’s share from the agreed ratio and compare it with both books.
  3. Reconcile the escrow or collection account: receipts in, partner remittances out, balance carried.
  4. Agree servicing fees and default loss guarantee positions, including invocations and replenishment.
  5. Compare SMA and NPA status for every loan and resolve differences before month-end reporting.
  6. Tie the reconciled shares to the control ledgers in the general ledger and to the bank books.
04 · BC PARTNERS

Business Correspondent partners: the same discipline

Where loans are sourced or collected through Business Correspondent (BC) partners, reconcile loans sourced and amounts collected per BC with the loan system, the collection account and the BC’s statements, and check commissions and settlement timelines. Field cash that has not reached the books is the most common gap.

See how this fits our wider NBFC reconciliation work, alongside LOS and LMS to general ledger, and statutory reconciliations such as income against TDS and fees against GST.

QUESTIONS

Frequently asked questions

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What is the minimum share each lender must keep in co-lending?

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Under the Reserve Bank of India (Co-Lending Arrangements) Directions, 2025, each co-lending partner must retain at least 10% of each loan.
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What is the default loss guarantee limit in co-lending?

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The originating lender may provide a default loss guarantee of up to 5% of outstanding loans in the co-lending arrangement.
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When do the RBI co-lending directions apply from?

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The Co-Lending Arrangements Directions, 2025 apply from 1 January 2026, with early adoption permitted.
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How quickly must co-lending partners share SMA or NPA status?

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Partners must share any change in a loan’s SMA or NPA status by the next working day, so both lenders classify the loan the same way.
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What does co-lending reconciliation cover?

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It covers loan-by-loan matching of the partner’s portfolio tape with the loan system, each partner’s share of principal, interest and charges, escrow or collection account flows, servicing fees, default loss guarantee positions, and SMA and NPA status, tied to the general ledger and bank books.
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What is Business Correspondent reconciliation?

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It matches loans sourced and collections made through each Business Correspondent partner with the NBFC’s loan system, collection account and the BC’s statements, and checks commissions and settlements.

Start with a diagnostic.

We review your books, controls and systems, and show you what your own Decision Brief would say. Each month Regi also writes The CFO Desk, a LinkedIn newsletter for owners running businesses in the Gulf, overseas and India.

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General information only. Not advice for your situation.

Regi Tom Antony & Associates is a firm of Chartered Accountants in Kochi, Kerala, practising since 1997. We act as virtual and fractional CFO to growing businesses in India, the GCC and overseas, and advise on NRI taxation and FEMA, SME IPOs, India entry for foreign companies, tax structuring, and family office and succession planning, alongside audit, tax and compliance.