BNPL at Checkout for Indian D2C Brands After the RBI's Simpl Order: What to Check

If your D2C store offers buy now, pay later (BNPL) at checkout, check who your partner is. On 25 September 2025 the Reserve Bank of India directed Simpl, a Bengaluru BNPL startup, to immediately stop all payment-related operations. The RBI said Simpl was running a payment system without the Certificate of Authorisation required under Section 4 of the Payment and Settlement Systems (PSS) Act, 2007. This is general information, not legal advice. Confirm your own position with your payment partner and a lawyer.

What did the RBI order Simpl to do?

According to Business Today, the RBI's letter is dated 25 September 2025 and directs Simpl to "immediately stop all payment-related operations". The order covers payment, clearing and settlement functions and took effect immediately.

The same report says:

• Simpl does not pursue an NBFC licence, unlike many BNPL rivals.
• Its merchant network reportedly included more than 26,000 partners.
• In July 2025 the Enforcement Directorate filed a case under FEMA against Simpl and its founder-director over alleged forex violations worth ₹913.75 crore. The company's response to that case is not in the article, and an allegation is not a finding.

What is not confirmed?

• Effect on merchants. The article does not say what the order means for merchants, pending settlements or refunds. Since settlement was among the halted functions, transactions routed through Simpl would be at risk, but the article does not confirm that.
• Current status. We could not find an RBI or Simpl statement that we could open on whether the order was lifted, changed or complied with. As of 9 November 2026 treat Simpl's status as not confirmed and ask your own provider.
• Other BNPL players. The order named only Simpl. It is not a ban on BNPL as a category.

Does BNPL still make sense for a D2C brand?

It can. BNPL and similar short-term credit lift conversion on higher-ticket baskets for some brands, but we do not have a sourced number for India and will not quote one. Test it on your own funnel instead.

The question is how it is delivered. A D2C brand can offer pay-later in a few ways:

Marketplaces already offer instalments. Amazon lists Flexible Customer Financing, giving no-cost EMI options on high-value items, among its seller programmes. If you sell the same product there, check how the cost compares with your own checkout.

What do RBI's rules say about how lenders must move money?

The RBI's Digital Lending Directions, 2025 (dated 8 May 2025) apply to commercial banks, co-operative banks, NBFCs and All-India Financial Institutions. Points that matter if your BNPL offer is a loan from a regulated lender:

• Regulated entities remain fully responsible for the acts of lending service providers (LSPs) they use.
• Disbursals and repayments generally go directly between the borrower and the regulated entity's bank account, not through an LSP or third-party account. Para 9(i) says the regulated entity shall ensure that in no case is disbursal made to a third-party account, including the accounts of the LSP.
• Borrowers get a cooling-off period of at least one day to exit a digital loan without penalty by paying principal and proportionate APR.
• Where an LSP shows offers from several lenders, it must present them so borrowers can compare and must avoid dark patterns.

These Directions are about digital lending by regulated entities. We have not confirmed how they apply to a specific merchant-side BNPL product. They are useful as a checklist for the right questions, not as a legal reading of your contract.

How do you vet a BNPL partner before adding it?

Ask these questions in writing and keep the replies.

1. Who is the regulated lender or payment system operator? Ask for the name and the RBI authorisation or NBFC registration. Check it yourself on the RBI website instead of taking a logo as proof.
2. How are you paid, and when? Settlement days, who holds the money in between, and whether funds sit in a nodal or escrow account.
3. Who bears non-payment? If the customer does not repay, is it the provider's loss or yours? Ask for "without recourse" in the contract if that is the claim.
4. What happens on a refund or return? Who refunds the customer, and does the provider reverse the settlement to you?
5. What is the fee, with GST? Merchant discount rate or flat fee, and who pays the subvention on no-cost offers.
6. What data do they collect? Under the Directions, data collection needs explicit consent and storage on servers in India. Ask where your customers' data goes.
7. What is the exit plan? If the provider is stopped, can you switch off the button quickly and recover unsettled amounts?

How should you set up checkout so one provider cannot sink it?

• Keep two ways to pay. UPI, cards and COD should work even if a BNPL button fails.
• Do not make BNPL the default. Show it as an option on higher baskets, not as the first choice for all orders.
• Reconcile weekly. Match settlements to orders, especially in the first month with a new provider.
• Watch the effect on COD. If BNPL pulls shoppers away from COD, your RTO may fall. Our COD to prepaid conversion tactics and COD vs prepaid margin calculator show how to measure it.
• Check payment links. Shiprocket's checkout lets customers send a payment request to friends or family, and the order stays the same. Whatever tool you use, test the failed-payment path.

FAQ

Is BNPL banned in India? No. The RBI's order of 25 September 2025 named Simpl, saying it ran a payment system without the required authorisation. Other providers work through banks, NBFCs or other authorised routes. Check each one.

Can I still use Simpl at checkout? We could not confirm Simpl's current status as of 9 November 2026. The September 2025 order told it to stop payment operations immediately. Ask your integration partner and Simpl in writing, and have a fallback.

What happens to money Simpl owes me? Not confirmed. The report we opened does not say what happens to pending settlements or refunds. Check your dashboard, raise the claim in writing and speak to your accountant about how to book it.

How do I check if a provider is authorised? Ask for the RBI Certificate of Authorisation or NBFC registration number and verify it on the RBI website. The PSS Act, 2007 requires authorisation for payment systems.

Does BNPL reduce RTO? Not proven. A prepaid-like method can reduce COD refusals, but we have no sourced figure for BNPL. Compare RTO on BNPL orders against COD orders in your own data over a few weeks.

Does BNPL cost the brand more than COD? Often yes in fees, but not always in total cost. COD carries a fee, RTO risk and remittance delay. BNPL carries a provider fee. Compare cost per delivered order for each, using the D2C contribution margin calculator.

Do the RBI Digital Lending Directions apply to me as a merchant? They apply to regulated lenders and their service providers. A merchant is not the regulated entity, but your provider's compliance affects you. Ask a lawyer how your contract fits.

Next step

Treat BNPL as one payment option, not the plan. Blooprint's Amazon account management team helps D2C brands compare how checkout choices change margin across marketplaces and their own store.