GRIP

India

Fintech

Most of what is called fintech in India sits on public payment rails and on someone else’s balance sheet.

Startup EcosystemsIndiaFintech

Rails and balance sheets

UPI, run by the National Payments Corporation of India, lets a private application move money between bank accounts. The application does not become the bank. Aadhaar and related identity systems make onboarding cheaper. They do not make a lender. Credit is a regulated balance sheet: a bank or a non-bank lender the Reserve Bank already supervises.

In May 2025 the Reserve Bank issued consolidated Digital Lending Directions. The press release describes a regime in which digital lending apps are tied to regulated entities, and a public directory of those apps so a customer can check the claim. Earlier guidelines already took the view that a lending service provider should not sit in the flow of funds between lender and borrower. A company that ‘does lending’ through an app is, in this system, usually a service provider or a regulated lender. The distinction is the business.

Where it is built

Mumbai is where the regulated institutions and SEBI sit. Bengaluru is where many of the applications are built. Delhi-NCR matters when the product touches public distribution, payments policy, or a ministry. GIFT City, under IFSCA, is a place to manage a fund or a financial service on an international-centre rulebook. It is not where a household in another state opens an account.

Account aggregation, payments, and credit underwriting are three products. Only the last one loses money when the borrower does not pay. Research that treats them as one ‘fintech wave’ is not usable.

Other sectors

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Cities and sectors are different maps.

A sector note says which rule and which customer. A city note says who can be hired. Neither is a ranking.