12.0 Phase 0 — Research and compliance design

Goal

Prepare the legal, regulatory, and vendor foundation so engineering can start in Phase 1 without surprises.

Features (deliverables)

• NBFC licence application filed (COSMOS), OR partner-NBFC LSP arrangement signed.
• Board, directors, fit-and-proper documentation complete.
• Compliance framework documented — see Section 2.
• Vendor shortlist done; commercials negotiated for key primitives (KYC, BSA, AA, GST, eSign, NACH).
• Sponsor bank engaged; account opening process initiated.
• Initial product specification done — see 1.7 WC and term.
• Initial credit policy v0 drafted.
• Engineering architecture document — see Section 5.
• 12-month financial plan; 36-month vision.

Integrations

• None live. Vendor sandbox access requested for top-3 vendors per category.

Team

• 2 founders / leadership.
• Compliance officer (advisor or hire).
• Senior engineering lead (technical co-founder or hire).
• External counsel + CS for licence / agreements.

Time

1 – 3 months. Longer if NBFC licence is required (licence cycle can be 6 – 24 months; in parallel, partner-LSP arrangement is a workaround).

Build vs buy

No code yet. Document the build-vs-buy decisions for each module.

Acceptance criteria

• Either CoR application filed OR partner agreement signed.
• Compliance baseline + risk policy approved by board.
• Vendor shortlist with negotiated commercials.
• Sponsor bank account opening initiated.
• Engineering architecture document approved.

Risks

• NBFC licence delays (6+ months of waiting).
• Vendor negotiation cycles longer than expected.
• Sponsor bank slow to onboard.

Go / no-go criteria for Phase 1

• Either CoR or LSP partner in hand (or close to closure).
• Compliance officer hired.
• Engineering team can start (lead hired; budget allocated).