Do payment apps need user consent for every transaction?

Generally no. Section 7 of the DPDP Act allows processing of data a user voluntarily provides for a specific purpose, such as completing a payment they started. Consent is needed for other uses, such as marketing, credit offers or sharing data with partners.

How does SecureCMS work inside a fintech app?

SecureCMS provides native iOS, Android and Flutter SDKs and APIs. The app shows consent screens through embedded or redirect flows, SecureCMS stores the consent per product and purpose, and the app or backend checks consent at runtime before using the data.

Is Account Aggregator consent the same as DPDP consent?

No. Account Aggregator consent covers sharing financial information through a licensed Account Aggregator under RBI's framework. When a fintech uses that data for its own purposes, DPDP duties on notice, purpose limitation and withdrawal still apply.

Who handles consent when a fintech partners with a bank or NBFC?

It depends on who decides the purpose. The fintech and the partner bank or NBFC can each be a Data Fiduciary for their own purposes. SecureCMS records which party each consent belongs to and syncs changes to partners.

Can a fintech delete a user's data on request if RBI rules require retention?

A fintech must erase data it no longer needs, but it can keep records a law requires, such as KYC records held after the relationship ends. SecureCMS logs which fields are kept, the legal reason and the release date, and erases the rest.

How do fintech apps handle users under 18?

For users under 18, the DPDP Act requires verifiable consent from a parent or lawful guardian and bars tracking, behavioural monitoring and targeted ads directed at children. SecureCMS has consent flows for minors and persons with disabilities that record guardian consent.

When do DPDP obligations apply to fintech companies?

The DPDP Rules were notified on 13 November 2025. Consent Manager provisions apply from 13 November 2026, and the remaining obligations, including notice, consent, rights and breach reporting, apply from 13 May 2027.

LIVE

Core DPDP Enforcement:13 May 2027

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DPDP Act 2023 & RBI HarmonizedUPI · Lending · Cards · Wealth

Consent Management Platform for Fintech Companies

Q: What is a consent management platform for fintech?

It is software that records what each user has agreed to across every product in a fintech app, checks that consent before data is used, passes changes to partner banks and tools, and keeps tamper-proof records. Fintechs use it to meet DPDP Act 2023 duties on notice, consent, withdrawal and user rights.

SecureCMS gives fintech apps one unified consent record per user across payments, lending, credit cards and wealth. Every consent change reaches your partner banks and downstream tools as it happens, engineered strictly for the DPDP Act 2023 and DPDP Rules 2025.

Regulatory Quick-Answer: Do Transactions Need Consent?

No separate consent popup is needed for user-initiated transactions. Under DPDP Section 7, payment execution is a legitimate use. However, using transaction history for credit cross-sell, loan offers or marketing legally mandates unbundled Section 6 affirmative consent.

Fintech Compliance Standards

Data Residency

MeitY Cloud (100% India)

RBI 2018 Directive Compliant

Sync Latency to Partner Banks

< 100ms via mTLS Webhooks

Real-Time Opt-Out Suppression

Card Data Security

Zero Card Storage Architecture

CoF Token Identifiers Only

Incubated & Evaluated By

DSCI Certified Member

CySecK Evaluated

IFSCA FinTech Cohort

IIT Kanpur C3iHub

Statutory Classification

Section 7 Legitimate Use vs Section 6 Mandatory Consent

The DPDP Act does not force you to prompt users for basic payments. Here is how statutory processing splits across fintech touchpoints.

Fintech Activity	DPDP Legal Basis	Consent Dialog Needed?	Compliance Rule
Completing a UPI or card payment initiated by user	Section 7 Legitimate Use (Voluntarily provided for specified purpose)	No separate popup needed	User actively triggers transaction; execution is contractually necessary. Notice still provided.
Cross-selling personal loans or credit cards using spend history	Section 6(1) Explicit Consent	Mandatory Unbundled Consent	Must be a distinct, unbundled opt-in checkbox. Cannot be bundled into Terms of Service.
Sharing transaction records with insurance or investment partners	Section 6(1) Explicit Consent + Co-Fiduciary Notice	Mandatory Partner Consent	Notice must identify third-party fiduciary categories and exact financial data items shared.
Credit bureau score pull (CIBIL / Experian / CRIF)	RBI Digital Lending Directions + Section 6 Consent	Mandatory OTP Verified Consent	Must be standalone, explicitly timed permission; no evergreen bureau harvesting.
Card-on-File (CoF) tokenization registration	RBI CoF Directive + Section 6 Consent	2FA / AFA Authentication Consent	Raw PAN never stored; consent binds token identifier and device binding.
Transaction monitoring for AML / CFT fraud detection	Section 7 Legitimate Use + PMLA Statutory Duty	Exempt from Consent	Statutory fraud prevention obligation overrides user opt-out rights.

Product × Purpose Isolation

One User, Many Products: The Consent Hierarchy

A single user often uses your app for payments, loans, and mutual funds. SecureCMS maintains granular consent separation so opt-outs in lending never break core payment functionality.

UPI & Peer-to-Peer Payments

Product Isolated

Data Collected:

Mobile number, VPA handle, transaction amount, beneficiary details

Primary Purpose:

Payment routing and settlement via NPCI / PSP bank

Statutory Framework:Section 7 Legitimate Use + NPCI Guidelines

Digital Lending & BNPL

Product Isolated

Data Collected:

PAN, Aadhaar offline KYC, bank statements, employment details, bureau score

Primary Purpose:

Credit underwriting, loan disbursement and repayment scheduling

Statutory Framework:Section 6 Explicit Consent + RBI Digital Lending 2025

WealthTech & Mutual Funds

Product Isolated

Data Collected:

PAN, KYC records, bank mandate, risk profile assessment, portfolio holdings

Primary Purpose:

Executing trade orders with AMCs, SEBI regulatory compliance

Statutory Framework:Section 6 Consent + SEBI KYC Master Directions

Co-Branded Credit Cards

Product Isolated

Data Collected:

Income documents, address proof, phone, delivery address

Primary Purpose:

Card issuance through partner scheduled commercial bank

Statutory Framework:Dual Fiduciary Agreement (Fintech LSP + Issuer Bank)

Real-Time Sandbox

Test Fintech Consent Lifecycle & Sync Telemetry

Toggle in-app permissions, watch instant partner bank webhook dispatch, and observe how statutory PMLA legal holds override premature user erasure.

Interactive Simulator

Fintech Multi-Product Consent & Partner Sync Engine

Experience unbundled consent isolation, RBI digital lending rules, and sub-100ms partner bank sync.

BharatPay Mobile App

v4.18 (SDK Active)

UPI Payment Processing

Executes user-triggered fund transfers via PSP bank and NPCI network.

Sec 7 Legitimate Use

Legal Basis: User-initiated transaction Essential

Pre-Approved Loan Offers

Use spending habits and transaction amounts to calculate instant credit limits.

Section 6 Unbundled Opt-InOpted Out

Credit Bureau Pull (CIBIL)

Standalone permission to fetch CIR score for loan eligibility check.

RBI 2025 Digital Lending RuleNo Bureau Access

Wealth Advisory & SIP Insights

Share cashflow metrics with partner SEBI RIA for mutual fund recommendations.

Third-Party Partner ConsentBlocked

Statutory Consent Boundary Architecture

Synced (Real-Time)

Notice how user-initiated payment processing operates unhindered under Section 7 Legitimate Use, eliminating user checkout drop-offs. In contrast, Credit Cross-Sell and Bureau Pulls strictly require unbundled opt-in switches under Section 6 and RBI 2025 guidelines.

Section 7 Status

Autonomous Execution

No consent friction for payments

Section 6 Audit Hash

sha256:4f8e...7b2a

Tamper-proof verifiable receipt

Real-Time Downstream Propagations

Partner Bank (Co-Branded Card Hub)mTLS Webhook: 200 OK (42ms)

Marketing & Notification Engine (CleverTap / MoEngage)Suppression: Active (Pushed)

Lending Underwriting Engine (LOS)Bureau Pull: Blocked

Platform Architecture

Enterprise Fintech Consent Modules

Modular components engineered specifically for high-throughput payment apps, neo-banks, and digital lending platforms.

Sub-100ms Sync

Omnichannel Consent Ledger

Single customer view across UPI, credit, cards and wealth. Every consent change cascades instantly to partner banks, CRM, and marketing systems.

Regulatory Guardrail

Section 7 vs 6 Policy Engine

Automatically separates transactions executed under legitimate use from commercial cross-sell that demands explicit affirmative opt-in.

RBI 2018 Compliant

RBI CoF & Zero-Card Vault

SecureCMS stores consent audit receipts and token references only. Never touches or stores unencrypted PCI-DSS cardholder PAN data.

PMLA / KYC Safe

PMLA Statutory Legal-Hold Engine

Automates Section 12 erasure requests while maintaining automated legal holds on 5-year statutory KYC and transaction ledgers.

Co-Fiduciary Ready

Partner Bank & NBFC Connectors

Bi-directional webhooks and mTLS REST APIs to sync borrower consent revivals and opt-outs with partner Core Banking Systems (CBS) and LMS.

iOS / Android / Flutter

Mobile App SDK Preference Center

Drop-in lightweight SDKs for iOS, Android, and Flutter. Gives users granular in-app toggles for marketing, analytics, and third-party sharing.

Embedded Finance Governance

Fintech as LSP vs Partner Bank as Regulated Entity (RE)

When a fintech distributes co-branded credit cards or personal loans, liability is split between the fintech front-end (acting as a Lending Service Provider or Co-Fiduciary) and the underwriting bank or NBFC.

Notice Identification: SecureCMS notices explicitly list both the fintech and partner bank fiduciary identities, fulfilling Section 5(1) disclosure duties.

Bilateral Opt-Out Routing: When a user revokes consent on the fintech app, SecureCMS dispatches signed webhook events directly to the bank's core system within 100ms.

Auditable Verification Receipts: Every consent change produces a cryptographic receipt admissible in dispute hearings before the Data Protection Board of India (DPBI) and RBI ombudsman.

CISO Security & Data Localization Layers

Data Localization Within India

100% cloud deployment in MeitY-empanelled Tier IV data centers in Mumbai and Hyderabad, complying strictly with RBI 2018 directive.

Cryptographic Consent Receipts

Every opt-in, revocation, and notice delivery is hashed using SHA-256 and signed with asymmetric key pairs for tamper-proof evidentiary proof.

Role-Based Access Control (RBAC)

Granular administrative privileges preventing customer support or sales reps from accessing unmasked financial identifiers.

Zero Card Data Storage

Engineered specifically so SecureCMS never stores card PANs, CVVs, or bank net-banking credentials; only consent lifecycle telemetry.

Statutory Timeline

6-Phase Fintech Implementation Roadmap

Structured deployment path to achieve complete DPDP compliance before the mandatory 13 May 2027 enforcement deadline.

Weeks 1–2Step 01

Phase 1: Data Discovery & Legal Mapping

Classify all fintech data flows into Section 7 (Legitimate Use) vs Section 6 (Consent Required).

Weeks 3–4Step 02

Phase 2: Multilingual Notice Configuration

Deploy unbundled statutory notices in English + 22 Eighth Schedule languages across mobile apps and web.

Weeks 5–6Step 03

Phase 3: Mobile SDK Integration

Embed iOS, Android, and Flutter SDKs; connect app preference center to SecureCMS REST endpoints.

Weeks 7–8Step 04

Phase 4: Partner Bank & NBFC Sync

Configure mTLS bi-directional webhooks with partner banks, card issuers, and lending underwriting engines.

Weeks 9–10Step 05

Phase 5: DSR & Legal-Hold Automation

Automate user rights management; link PMLA 5-year retention rules to prevent unlawful premature erasure.

Weeks 11–12Step 06

Phase 6: CISO Security Audit & Go-Live

VAPT certification, end-to-end sync stress testing, and board-level compliance sign-off ahead of 13 May 2027.

Related DPDP Compliance Modules

DPDP Compliance Platform for Banks

Core banking consent architecture, CBS connectors, and RBI compliance.

Consent Management Platform for NBFCs

RBI Digital Lending Directions 2025, zero-scraping onboarding, and LSP sync.

SecureCookie CookieHub

Cookie consent and banner automation for financial web portals.

DPDP Readiness Assessment

Diagnostic toolkit and gap analysis for Indian financial fiduciaries.

Official Statutory Sources

Digital Personal Data Protection Act 2023 (Gazette of India)Draft DPDP Rules 2025 (Ministry of Electronics and IT)RBI Directive on Storage of Payment System Data (April 2018)RBI Guidelines on Digital Lending (Updated 2025)

Frequently Asked Questions

Frequently Asked Questions for Fintech Teams

It is software that records what each user has agreed to across every product in a fintech app, checks that consent before data is used, passes changes to partner banks and tools, and keeps tamper-proof records. Fintechs use it to meet DPDP Act 2023 duties on notice, consent, withdrawal and user rights.

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