Last update: Jun 8th, 2026

Interest Rate Policy

A. Preamble

The Reserve Bank of India (“RBI”) has, vide the Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023 (as amended from time to time) (“RBI Master Directions”), advised Boards of Non-Banking Financial Companies (“NBFCs”) to adopt an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium, and to determine the rate of interest to be charged for loans and advances. The RBI Master Directions further require that the rate of interest and the approach for gradation of risk, and the rationale for charging different rates of interest to different categories of borrowers, be disclosed to the borrower/customer in the application form and communicated explicitly in the sanction letter.

In order to ensure standards of transparency, in conformity with the RBI Master Directions and the Fair Practices Code adopted by Padmalaya Finserve Private Limited (“Padmalaya” or “the Company”), and consistent with the RBI (Digital Lending) Directions, the Company has adopted this Interest Rate Policy (“Policy”) for determining interest rates, processing fees, service fees and other charges, and for broadly outlining the Company’s interest rate model and its approach to risk gradation for its Personal Loan (“PL”) product, disbursed through the “Bridge” application.

This Policy shall be effective from the date of its approval by the Board of Directors of the Company and shall be subject to amendment in accordance with regulations, circulars, notifications, and other directions issued by regulatory authorities from time to time. In the event of any inconsistency between the provisions of this Policy and any such amendment, circular or clarification, the latter shall prevail over the provisions of this Policy.


B. Objective

  • To arrive at the benchmark rates to be used for different categories of PL borrowers, and to determine the principles and approach for charging spreads to arrive at the final rate charged to a borrower.

  • To communicate the annualised rate of interest to the borrower, together with the approach for gradation of risk and the rationale for charging different rates of interest to different categories of borrowers.

  • To make available the rates of interest and the approach for gradation of risk on the Company’s website.


C. Computation of the Interest Rate

The Company’s Interest Rate Model broadly takes into account the following components:

S. No.
Particulars
Description

1

2

3

4

Weighted Average Cost of Funds (WACF)

Opportunity Cost of Cash Reserves

Operating Cost net of Processing Fee

Net Credit Risk Premium

Represents the Company’s blended cost of capital across all sources, including equity and debt, each weighted by its percentage of total capital. The Cost of Debt represents the interest rate and other costs associated with borrowings used for lending operations, including costs of raising such funds. The Company’s equity, comprising infused capital and retained earnings, is also considered for its proportionate share. WACF = ((Debt Proportion × Cost of Debt) + (Equity Proportion × Cost of Equity)) / (Total Debt + Equity).

The Company maintains cash reserves for liquidity purposes. These reserves carry an opportunity cost, as they remain unutilised for lending and may generate little to no interest income, creating a negative carry that is factored into the interest rate.

Represents the expenses incurred by the Company in its day-to-day lending activities, including marketing, loan origination, processing, servicing, collections, customer support and overhead costs, net of the revenue recovered through processing fees. This represents the residual cost burden to be covered through interest income.

Accounts for the risk of borrower default and represents the expected loss from a loan in the event of delinquency, arrived at from internal assessment of market present segment wise portfolio performance, default trends and customer relationship. The risk of default is adjusted for recoveries from customers in the form of penal/late charges, and only the net credit risk premium is factored into the interest cost.

S. No.

Particulars

Description

1

2

3

4

Weighted Average Cost of Funds (WACF)

Opportunity Cost of Cash Reserves

Operating Cost net of Processing Fee

Net Credit Risk Premium

Represents the Company’s blended cost of capital across all sources, including equity and debt, each weighted by its percentage of total capital. The Cost of Debt represents the interest rate and other costs associated with borrowings used for lending operations, including costs of raising such funds. The Company’s equity, comprising infused capital and retained earnings, is also considered for its proportionate share. WACF = ((Debt Proportion × Cost of Debt) + (Equity Proportion × Cost of Equity)) / (Total Debt + Equity).

The Company maintains cash reserves for liquidity purposes. These reserves carry an opportunity cost, as they remain unutilised for lending and may generate little to no interest income, creating a negative carry that is factored into the interest rate.

Represents the expenses incurred by the Company in its day-to-day lending activities, including marketing, loan origination, processing, servicing, collections, customer support and overhead costs, net of the revenue recovered through processing fees. This represents the residual cost burden to be covered through interest income.

Accounts for the risk of borrower default and represents the expected loss from a loan in the event of delinquency, arrived at from internal assessment of market present segment wise portfolio performance, default trends and customer relationship. The risk of default is adjusted for recoveries from customers in the form of penal/late charges, and only the net credit risk premium is factored into the interest cost.

S. No.
Particulars
Description

1

2

3

4

Weighted Average Cost of Funds (WACF)

Opportunity Cost of Cash Reserves

Operating Cost net of Processing Fee

Net Credit Risk Premium

Represents the Company’s blended cost of capital across all sources, including equity and debt, each weighted by its percentage of total capital. The Cost of Debt represents the interest rate and other costs associated with borrowings used for lending operations, including costs of raising such funds. The Company’s equity, comprising infused capital and retained earnings, is also considered for its proportionate share. WACF = ((Debt Proportion × Cost of Debt) + (Equity Proportion × Cost of Equity)) / (Total Debt + Equity).

The Company maintains cash reserves for liquidity purposes. These reserves carry an opportunity cost, as they remain unutilised for lending and may generate little to no interest income, creating a negative carry that is factored into the interest rate.

Represents the expenses incurred by the Company in its day-to-day lending activities, including marketing, loan origination, processing, servicing, collections, customer support and overhead costs, net of the revenue recovered through processing fees. This represents the residual cost burden to be covered through interest income.

Accounts for the risk of borrower default and represents the expected loss from a loan in the event of delinquency, arrived at from internal assessment of market present segment wise portfolio performance, default trends and customer relationship. The risk of default is adjusted for recoveries from customers in the form of penal/late charges, and only the net credit risk premium is factored into the interest cost.

Interest Rate to Borrower

The final interest rate charged to the borrower (annualised rate) includes all of the components described above:

Interest Rate to Borrower = WACF + Annualised Cost of Cash Reserves + Annualised Operating Cost net of Processing Fee + Annualised Net Credit Risk Premium

The interest rate is further calibrated within the Company’s risk-based pricing framework (see Section H below), such that borrowers assessed as lower risk are ordinarily offered a rate towards the lower end of the applicable range, and borrowers assessed as higher risk (but still within the Company’s risk appetite) a rate towards the higher end. The interest rate so determined for the PL product is listed for quick reference in Annexure–1.


D. Processing Fees

The cost of sourcing and handling a loan application is recovered from the customer as a processing fee. Several processes are undertaken to assess and verify every customer prior to approval, and the costs incurred in implementing these processes are recovered from customers whose loans are approved, in the form of a processing fee. The processing fee may vary based on the loan amount, customer segment, tenor and the risk associated with the application, and generally represents the cost incurred by the Company in rendering the PL facility to the customer.

The Processing Fee is currently charged at up to 15% of the sanctioned amount, excluding GST. Management regularly reviews the processing fee and may revise it at any time; any revision shall be applied prospectively, with due communication to customers. All processing, documentation and other charges recovered are expressly stated in the loan documents. All applicable taxes shall be charged in accordance with guidelines issued by the Government from time to time.


E. Service Fee

In addition to the Processing Fee, the Company shall levy a Fee for services rendered in connection with serving the PL facility (including platform access, platform maintenance, cloud cost, account monitoring and repayment-facilitation services). The Service Fee currently accrues at 60% per annum on the sanctioned amount, computed on a pro-rata basis for the actual tenure of the loan, and is levied and collected solely by the Company. For the Company's standard 2-month PL tenure, this results in an effective Service Fee of approximately 10% of the sanctioned amount paid across 2 instalments, before GST.

Consistent with the RBI Digital Lending Directions which prohibit a Lending Service Provider (“LSP”) from directly charging any fee to the borrower, both the Processing Fee and the Service Fee are levied and collected only by the Company, and are fully reflected in the Key Fact Statement (“KFS”)/Annual Percentage Rate (“APR”) disclosed to the borrower. Any amount payable by the Company to its LSP for origination and technology-facilitation services under the Board-approved LSP agreement is borne by the Company out of the aforesaid fees/interest income, and is not charged separately to the borrower.


F. Penal Charges

For any delay in payment beyond the due date specified in the repayment schedule, the following charges apply to the overdue amount, from the date of default to the date of actual payment:

  • Post Default Interest: the contracted Rate of Interest continues to accrue on the overdue principal amount.

  • Repayment Bounce Penal Charge: Post default, the Service Fee ceases to accrue with effect from the date of default; the same 60% p.a. accrual on the overdue principal continues without interruption, but is thereafter characterised as the Repayment Bounce Penal Charge rather than the Service Fee. This is accordingly a continuation, not an addition, of the pre-default Service Fee.

  • Late Payment Fine: an additional 36% p.a. on the overdue instalment amount, subject to a discretionary three-day waiver at the Company's determination.

None of the above charges are capitalised or compounded; no further interest is computed on the charges themselves, though this does not affect their accrual over the period the amount remains due. The quantum and applicability of each charge is disclosed to customers in the loan agreement and the sanction letter/KFS.


G. Other Charges

Other charges constitute bounce charges, prepayment/foreclosure charges and the like, and are charged to the customer with due intimation through the KFS. Any charge not forming part of the KFS shall only be levied after obtaining the customer’s prior consent.

  • Prepayment/Foreclosure Charge – No additional prepayment/foreclosure charges apply.

  • NACH/UPI Autopay mandate-bounce or swap charges – ₹500 per instance.

  • Payment Gateway charges on actuals

  • Legal and collection charges actually incurred, where applicable.


H. Gradation of Loan Based on Risk Assessment

The Company grants credit facilities to individual borrowers who demonstrate both the intention and the ability to discharge their obligations. The PL product is granted on an unsecured basis, in accordance with the Company’s Credit Policy. Every applicant’s risk grading is assessed through checks conducted during the KYC and onboarding process, resulting in a Low/Medium/High risk categorization. In assessing credit transactions, the Company focuses on the following principles:

  • a detailed profile of the borrower at the time of onboarding, with due diligence in accordance with the Company’s KYC/AML Policy;

  • for repeat customers, the tenure of the relationship, past repayment track record, and the historical performance of similar customer segments;

  • repayment capacity, sources of income, and other financial commitments of the borrower;

  • the default risk associated with the borrower’s income/employment segment;

  • additional data-based signals, including credit bureau information and, where applicable and with consent, transactional SMS data, bank statement/Account Aggregator data and other alternate data sources;

  • rates may also vary having regard to prevailing rates offered by other lenders in comparable segments; and

  • any other factor considered relevant in a particular case, or as the Company may deem fit.


J. Disclosure to Borrower

The Company shall inform each borrower, in writing, in English and in a vernacular language as understood by the borrower, and as otherwise required under applicable law, of all relevant details in relation to the PL facility, including all necessary documentation to be executed in connection with the loan (i.e., loan agreement, sanction letter/KFS, along with all relevant enclosures). This Policy shall be made available on the Company’s website.


K. Review of Policy

This Interest Rate Policy is subject to annual review, based on the recommendation of the Company’s Credit Committee reporting to the Board. The Policy may be reviewed earlier were necessitated by a change in regulatory guidelines or in the Company’s business practices. Notwithstanding anything contained in this Policy, in the event of any contradiction between the provisions of this Policy and any existing legislation, rules, regulations or law (or any modification or enactment thereof), the provisions of such law, legislation, rule or regulation shall prevail over this Policy.

ANNEXURE I

ANNEXURE I

CURRENT BOARD-APPROVED RATES & CHARGES

CURRENT BOARD-APPROVED RATES & CHARGES

Interest Rate p.a.
Tenure
Processing Fee
Service Fee
Ticket Size

60%p.a. to 67%p.a. %

2 months (fixed)

15% + GST

60%p.a. + GST

₹3,000 to ₹15,000

Interest Rate p.a.

Tenure

Processing Fee

Service Fee

Ticket Size

60%p.a. to 67%p.a. %

2 months (fixed)

15% + GST

60%p.a. + GST

₹3,000 to ₹15,000

Interest Rate p.a.

Tenure

Processing Fee

Service Fee

Ticket Size

60%p.a. to 67%p.a. %

2 months (fixed)

15% + GST

60%p.a. + GST

₹3,000 to ₹15,000

This Annexure will be populated with the Credit Committee reporting to the Board - approved figures and kept updated on the Company’s website whenever rates or charges change, in accordance with the Fair Practices Code.

This Annexure will be populated with the Credit Committee reporting to the Board - approved figures and kept updated on the Company’s website whenever rates or charges change, in accordance with the Fair Practices Code.