A few years in financial services teaches you one thing faster than anything else: access and adoption are not the same problem. We have built access before. Repeatedly. Jan Dhan opened 500 million accounts. UPI scaled to billions of transactions. Each time, the system got faster, broader, and more connected. And each time, the adoption curve lagged, because the experience didn't keep up with the infrastructure. The Unified Lending Interface (ULI) will face the same test. Whether it passes depends less on the RBI and more on what we fintechs sitting on top of these rails choose to build.
What ULI actually fixes
Let me be specific, because the coverage has been vague. The bottleneck in credit was never demand. India has enormous, unmet demand for credit, from small traders, gig workers, first-time borrowers, and people with thin or fragmented financial histories. The demand was always there. The bottleneck was data. Not an absence of data, but its fragmentation. A borrower's income signals sit on one platform. Their repayment history sits on another. GST filings sit somewhere else. Land records sit in a government database that nobody queries in real time. No lender could see the full picture, so most lenders defaulted to the safe call: decline, or approve less at a higher rate. ULI creates a consent-based pipeline to pull these signals together, in minutes, not days. That's the fix. It's real, and it matters. A working capital loan that arrives ten days late isn't a solution. In credit, timing is everything.
But infrastructure is not the product
Here's where I would push back on some of the optimism I'm seeing. UPI didn't change financial behaviour because the rails were good. It changed behaviour because enough good products got built on top—simple, fast, trustworthy products that people actually wanted to use. The rails were necessary. They weren't sufficient.
ULI will be the same. Better data pipelines make credit faster. They don't, on their own, make it better.
A borrower who doesn't understand what data they just consented to share is not empowered, they’re exposed. A loan approved in three minutes but structured for the wrong tenure and ticket size doesn't serve their needs. It serves a disbursement target.
The three questions that will actually determine ULI's impact:
1.Does the borrower understand what they're signing? Not the fine print, the actual substance. What data, why, and what it means for them.
2.Is the product matched to their reality? A daily-wage earner doesn't need a standard 12-month EMI. They need a repayment structure that maps to how they actually earn.
3.Does the borrower come back? First credit experiences stick. If it works and the borrower trusts it, they become a long-term customer of formal credit. If it doesn't, you've confirmed every suspicion they already had.
That last one is the one I would watch most closely.
What fintechs have to own
We run a fintech that serves first-time borrowers—people the traditional system largely ignored. ULI improves our ability to assess them. Good. We'll use it. But I am under no illusion that better assessment automatically means better outcomes. That part is on us.
Practically, that means three things:
1.Design for comprehension, not just conversion. Consent flows that get clicked through without being understood aren't consent. They're a liability for the borrower first, and for the lender eventually.
2.Use better data to build better-fit products. Not just to approve faster. If ULI gives us richer income signals, we should use them to structure products that actually match cash flows, not to push volume through at thinner margins.
3.Take responsible lending seriously before the regulator makes you. The data advantage that ULI creates will tempt some players to extend credit they shouldn't. That always ends the same way: stress in the book, regulatory scrutiny, and borrowers who were already fragile getting pushed further under.
I have seen this cycle. And I would rather not run through it again.
The stakes are higher than the metrics suggest
Here's the thing about the population ULI is meant to reach. They don't get multiple chances to form a first impression of formal credit. If the system works for them, clearly, fairly, on time, it changes how they think about credit for the rest of their financial lives. That's the real prize. Not the disbursement number in year one. If it doesn't work, if it's confusing, or extractive, or just slightly off from what they actually needed, they don't come back. They go back to the money lender, or the family loan, or nothing. And the narrative that formal credit isn't really for people like them gets reinforced.
We cannot afford that outcome. Not again.
ULI is, genuinely, one of the better pieces of financial infrastructure India has built. The question now isn't whether the plumbing works. The question is whether we have the discipline to build something worthy of it.
Amit Lodha, Co-Founder & Group CEO, FatakPay.
