Build Roadmap

The build order should follow regulatory risk and state ownership, not UI convenience. A lender can survive a plain-looking UI; it cannot safely book loans without consent, KYC, KFS, disbursement controls, LMS ledger, DPD, audit trail and reporting evidence.

The roadmap below assumes a greenfield modular build using the boundaries in module map. Each slice names the exact entities, states, integrations and tests needed before the slice is considered shippable.

Build Principles

Principle	Roadmap consequence
One source of truth per domain	Build party, KYC, documents, LOS, LMS and collections ownership before partner/co-lending overlays.
Regulatory evidence first	audit_event, consent_artifact, kfs_version, maker-checker and immutable document storage ship before high-volume automation.
State machines before dashboards	Implement legal transitions for application_state, loan_account.account_state, delinquency states and collections states before operational MIS.
Manual plus controlled automation	MVP may use manual upload or vendor console for some rails, but system must still capture normalized evidence, consent and audit.
Co-lending after core loan correctness	Partner shares and escrow split depend on correct sanction, disbursement, schedule, receipts, DPD and closure.

Slice 0: Platform And Control Spine

Item	Specification
Goal	Establish identity, audit, authorization, configuration and document storage foundations.
Modules	IAM, audit service, configuration master, document service/DMS, notification skeleton.
Entities	party, natural_person, business_entity, address, document_instance, document_requirement, consent_artifact, audit_event, authority_level, authority_rule, approval_request, approval_decision.
Actor roles	system_admin, internal_auditor, sales_ops, kyc_maker, kyc_checker, ops_maker, ops_checker, compliance_officer, system_service.
Deliverables	RBAC/ABAC guard engine, maker-checker workflow, immutable audit event writer, encrypted document vault, reason-code master, product/geography/branch masters.
Exit tests	User cannot self-grant approver role; document correction creates new document_instance; approval checker cannot be same user as maker; audit event reconstructs before/after hash.
Rationale	Every later slice needs audit, documents, roles and approvals. Retrofitting these after loan volume creates unfixable evidence gaps.

Slice 1: Lead, Consent, Prescreen And KYC

Item	Specification
Goal	Convert leads into compliant applications through lead_created, prescreen_pending, prescreen_passed, kyc_pending and docs_pending.
Modules	Channel CRM, LOS workflow, consent and privacy service, KYC and AML service, BRE basic gates.
Entities	application, application_party, kyc_profile, beneficial_owner, screening_hit, external_verification, bre_result, workflow_task, queue_assignment.
Integrations	PAN validation, bureau soft/hard enquiry where policy permits, CKYC search, sanctions/PEP/adverse media, Udyam verification optional for MVP but schema-ready.
Workflow states	lead_created, prescreen_pending, prescreen_passed, kyc_pending, docs_pending, returned_for_rework, on_hold, rejected, withdrawn, expired.
Deliverables	Lead intake, dedupe, consent capture, required-party creation by constitution, BO workflow, screening hit resolution, KYC maker-checker, basic document checklist.
Exit tests	Legal entity cannot leave kyc_pending with unverified beneficial_owner; revoked consent blocks bureau pull; sanctions true positive blocks kyc_verified; duplicate lead creates dedupe match rather than duplicate application.
Rationale	KYC, consent and eligibility are regulatory entry gates. A lender should reject or rework early before collecting full data or spending credit effort.

Slice 2: Data Pack, BRE And Credit Workbench

Item	Specification
Goal	Build complete underwriting evidence and decisioning from data_pending through credit_in_review, deviation_pending and approved.
Modules	Integration gateway, BRE and decision service, credit workbench, RCU hooks, financial spreading.
Entities	external_verification, credit_assessment, bre_result, deviation, financial_spread, cam, approval_request, approval_decision.
Integrations	Consumer/commercial bureaus, Account Aggregator, bank statement analyzer, GST analytics, ITR/upload parser, MCA, Udyam.
Workflow states	data_pending, credit_in_review, deviation_pending, approved, rejected, returned_for_rework, on_hold.
Deliverables	Data requirement matrix by product and constitution, provider retry engine, normalized underwriting variables, CAM builder, rule versioning, scorecard placeholder, DoA resolution.
Exit tests	Provider retry exhaustion emits provider_retry_exhausted; non-waivable hard policy fail moves to rejected; deviation approval requires resolved authority; CAM freezes data pack version.
Rationale	This slice produces defensible credit decisions. It can initially support one product, but must use versioned rules and evidence from day one.

Slice 3: Sanction, KFS, Documentation And CPs

Item	Specification
Goal	Move approved cases to borrower-accepted sanction and executed documentation.
Modules	Credit workbench, KFS archive, documentation and execution service, document service, customer portal/DLA.
Entities	sanction, sanction_condition, kfs_version, document_checklist, stamp_certificate, signature_event, guarantee, documentation_exception, mandate.
Integrations	DigiLocker, eSign, eStamp, eNACH/NACH mandate registration, bank account verification/penny drop.
Workflow states	approved, sanctioned, sanction_accepted, documentation_pending, on_hold, returned_for_rework, expired.
Deliverables	Sanction template, KFS APR computation, KFS validity/acceptance, execution checklist, CP/CS tracking, eSign/eStamp callbacks, mandate setup.
Exit tests	KFS change supersedes old version and requires fresh acceptance; staff cannot accept KFS on borrower behalf; mandate rejection blocks disbursement unless approved exception exists; document hash mismatch invalidates eSign completion.
Rationale	RBI KFS and digital disclosure duties are borrower-protection controls. They must be complete before the first production booking.

Slice 4: Disbursement And LMS Booking MVP

Item	Specification
Goal	Book a loan safely with payment, schedule, GL event and borrower communication.
Modules	Disbursement service, LMS core, Finance and GL adapter, notification service.
Entities	loan_account, facility, disbursement, schedule_version, repayment_due, loan_transaction, appropriation_allocation, bank_account_verification, payment_instruction, accounting_event, gl_posting.
Integrations	NEFT/RTGS/IMPS/UPI/bank host-to-host disbursement rail, payment status enquiry, bank reconciliation feed.
Workflow states	disbursement_pending, pending_booking, active_undisbursed, partially_disbursed, active_current, cancelled.
Deliverables	Disbursement maker-checker, direct beneficiary rules, LMS account creation, schedule generation, first due date, GL posting, welcome communication, idempotent payment callbacks.
Exit tests	Disbursement to LSP account is rejected; duplicate callback does not duplicate loan_transaction; failed payment triggers booking_failed; account cannot be active_current without valid schedule.
Rationale	Loan booking is the point of no return. Correct ledger, schedule and fund-flow behavior must precede scale, partner APIs or collections automation.

Slice 5: Servicing, Dues, Receipts And Delinquency

Item	Specification
Goal	Generate demands, post receipts, calculate DPD/SMA/NPA and open collections cases.
Modules	LMS core, servicing, payment collection, collections platform intake, finance reconciliation.
Entities	repayment_due, loan_transaction, appropriation_allocation, asset_classification, mandate, service_request, delinquency_snapshot, collection_case.
Integrations	NACH debit, UPI collect/payment links, bank virtual account, payment gateway status, CIC file skeleton.
States	Loan: active_current, active_overdue, frozen, preclosed, matured_pending_closure, closed; delinquency: current, x_bucket, dpd_1_30, dpd_31_60, dpd_61_90, npa_90_plus, closed; collections: not_open, open_unallocated.
Deliverables	Demand batch, receipt posting, bounce events, appropriation rules, DPD recomputation, SMA/NPA mapping, pre-due reminders, case creation, statement/NOC requests.
Exit tests	Partial payment leaves state in correct DPD band; NPA upgrade only after all arrears clear; collections cannot edit DPD; same-day cash recovery reflection control exists.
Rationale	The lender’s risk, accounting, CIC reporting and collections all depend on objective LMS-driven delinquency.

Slice 6: Collections Operations MVP

Item	Specification
Goal	Operate tele/field collections, PTPs, escalations, settlements and legal readiness without changing LMS truth.
Modules	Collections platform, agency portal, legal recovery workflow, approval service.
Entities	collection_case, case_allocation, contact_attempt, ptp, settlement_proposal, workflow_task, approval_request, approval_decision, loan_transaction for waiver/write-off posting.
States	open_unallocated, allocated_tele, allocated_field, ptp_active, ptp_broken, escalated_hard_bucket, legal_review, settlement_review, restructure_review, repossession_or_enforcement, terminal closure states.
Integrations	Payment links, call/SMS/WhatsApp logs, field visit evidence, legal notice document generation, NeSL default evidence optional.
Deliverables	Strategy allocation, agent scope, borrower recovery-agent notification, PTP tracking, field visit evidence, settlement DoA, write-off maker-checker, conduct audit.
Exit tests	Recovery agent assignment notification precedes first contact; broken PTP escalates; OTS approval cannot be done by negotiator alone; settlement funds must be posted by LMS before closed_settled.
Rationale	Collections adds conduct risk. Build it after DPD truth exists so agents cannot manipulate classification.

Slice 7: Compliance Reporting And Regulatory Ops

Item	Specification
Goal	Produce KFS archive, CIC submissions, DLA inventory, regulatory return runs and consent/audit evidence.
Modules	Compliance, audit and reporting; Finance and GL adapter; consent service.
Entities	audit_event, regulatory_report_run, cic_submission, kfs_version, complaint, access_review, consent_artifact.
Integrations	CIC reporting exchange, RBI CIMS return metadata, CKYC upload/update, CERSAI/NeSL where enabled.
Deliverables	Reporting calendar, file generation, reject correction, DQI tracking, complaint SLA, access review, evidence pack export.
Exit tests	CIC rejected record creates correction task; DLA cannot go live without CIMS inventory data; audit export is read-only; access review identifies dormant and conflicting roles.
Rationale	Reporting can be built after core events exist, but before high volume. The first audited period should not require manual reconstruction.

Slice 8: Secured SME Extension

Item	Specification
Goal	Support LAP, machinery, stock/book-debt security and charge perfection.
Modules	Collateral and security service, legal/valuation vendor portals, documentation, LMS servicing.
Entities	collateral_asset, collateral_owner, valuation_report, legal_opinion, security_charge, cersai_filing, roc_charge_filing, insurance_policy, executed_document, vault_packet.
Integrations	CERSAI search/filing/satisfaction, MCA charge lookup, eStamp/eSign, insurance verification, valuer/legal vendor upload.
States	Application: credit_in_review, documentation_pending, disbursement_pending; collateral: proposed, documents_pending, under_legal_review, under_valuation, approved, approved_with_conditions, charged, released; loan closure states.
Deliverables	Collateral checklist, title/valuation workflow, charge creation/perfection, insurance tracking, original document vault, secured closure and release workflow.
Exit tests	Secured loan cannot disburse without security_charge.perfection_status acceptable under policy; CERSAI rejection creates legal/ops task; collateral release requires no-dues, legal and finance checks.
Rationale	Secured products add legal, valuation and registry dependencies. They should not block unsecured MVP but must be first-class before LAP launch.

Slice 9: Partner, LSP And Co-Lending Extension

Item	Specification
Goal	Add partner APIs, anchor programs, co-lending shares, escrow split, DLG ledger and partner reconciliation.
Modules	Partner API gateway, co-lending and partner ledger, Finance and GL adapter, compliance reporting.
Entities	partner_profile, partner_program, api_client, partner_application_ref, co_lending_arrangement, partner_share, escrow_movement, partner_ledger, dlg_set, dlg_portfolio_loan, dlg_invocation, partner_status_event, payout_ledger.
Integrations	Partner APIs/webhooks, escrow bank statement, partner statement import, CIC per-share reporting, DLG provider acknowledgement.
States	Application channel_type=co_lending, lsp, anchor; loan states from booking through closure; collections partner sync events.
Deliverables	Partner onboarding, API auth/scopes, dual-decisioning, blended KFS, partner share booking within 15 calendar days, escrow reconciliation, DLG cap checks, payout and clawback.
Exit tests	95:5 CLA rejected; partner share missing after 15 days creates break; partner cannot see raw CAM/bureau data; DLG invocation cannot exceed 5 percent cap; SMA/NPA event delivered by next working day.
Rationale	Co-lending depends on correct core loan, KFS, payment, DPD, GL and reporting. Building it earlier creates duplicate ledgers and reconciliation debt.

Slice 10: Monitoring, EWS, Renewal And Portfolio Risk

Item	Specification
Goal	Add post-booking risk monitoring, early-warning signals, covenant tracking, renewals and portfolio analytics.
Modules	Monitoring/EWS, BRE monitoring, risk analytics, servicing, credit workbench.
Entities	sanction_condition, credit_assessment, bre_result, external_verification, service_request, schedule_version, asset_classification, monitoring trigger records.
Integrations	AA periodic consent, GST monitoring, bureau refresh where consent/policy permit, stock statement upload, insurance renewal.
Deliverables	Covenant calendar, stock statement tracker, GST/banking drop alerts, renewal/top-up workflow, risk-grade migration, portfolio caps.
Exit tests	Monitoring fetch blocked without active consent; covenant breach creates task and may freeze facility; renewal starts fresh application or approved renewal workflow, not silent limit extension.
Rationale	Monitoring improves portfolio quality but requires live loan data and consent controls already present.

MVP Product Recommendation

Dimension	MVP choice	Reason
Product	Unsecured business loan or small ticket machinery/term loan without collateral charge automation	Exercises KYC, bureau, bank/GST/ITR data, KFS, sanction, eSign, mandate, disbursement, LMS, DPD and collections without CERSAI/ROC complexity.
Channel	Branch/digital direct plus controlled DSA	Tests customer, sales and DSA permissions while avoiding partner API/co-lending complexity.
Borrower constitutions	Proprietorship, partnership, LLP, private limited	Covers natural person, business entity, BO, promoter/director/partner and guarantor paths.
Integrations	PAN, bureau, CKYC, sanctions, bank statement/AA, GST, eSign/eStamp, eNACH, payment rail	Covers core underwriting and booking evidence. ITR, Udyam, DigiLocker can be added if vendor/onboarding is ready.
Collections	Tele, PTP, field allocation, settlement proposal	Enough to prove DPD-driven operations and conduct controls.

Release Gates

Gate	Must pass before production
Regulatory gate	KYC, consent, KFS, fund-flow, audit, DPD/NPA and grievance controls pass compliance test cases.
Ledger gate	Disbursement, schedule, receipt, reversal, waiver, GL and bank reconciliation are idempotent and balanced.
Security gate	RBAC/ABAC tests, maker-checker, encryption, secrets, log redaction, partner scope and vulnerability checks pass.
Data gate	Mandatory fields for party, application, loan_account, repayment_due, loan_transaction, asset_classification, kfs_version and audit_event are complete.
Reporting gate	CIC extract dry run, KFS evidence pack, DLA inventory, access review and audit export work without manual spreadsheet patching.
Operations gate	Queue SLAs, rework, holds, escalations, failure retries and support runbooks are tested.

Build Order Summary

Order	Slice	Why now
0	Platform and control spine	Shared audit, IAM, approvals and document vault are prerequisites.
1	Lead, consent, prescreen and KYC	Establish regulated borrower onboarding and early rejection.
2	Data pack, BRE and credit	Create defensible underwriting and approval evidence.
3	Sanction, KFS and documentation	Meet borrower disclosure and execution requirements.
4	Disbursement and LMS booking	Create account, schedule, ledger and direct fund flow.
5	Servicing and delinquency	Generate dues, receipts, DPD, SMA/NPA and case triggers.
6	Collections operations	Operational recovery using LMS truth.
7	Compliance reporting	Generate reports from source events before scale.
8	Secured SME	Add collateral, legal, valuation and charge perfection.
9	Partner/co-lending	Add partner shares, escrow, DLG and reconciliation after core loan correctness.
10	Monitoring/EWS	Add portfolio defence and renewal intelligence.

Sources

• RBI, Reserve Bank of India (Digital Lending) Directions, 2025
• RBI, Key Facts Statement (KFS) for Loans & Advances, April 15, 2024
• RBI, Reserve Bank of India (Co-Lending Arrangements) Directions, 2025
• RBI, Master Direction - Know Your Customer (KYC) Direction, 2016