Security Consulting & Compliance
DL-SAR Compliance Audit
Digital lending self-assessment report audit and attestation.
Every engagement includes manual validation, a two audience report and free re-testing.
Get a scoped quote+91 96682 00222What this actually is
The RBI's digital lending directions require regulated entities and their lending service providers to submit an annual System Audit Report covering the technology behind the lending journey.
The scrutiny is on the borrower's experience and their data. Whether the Key Fact Statement is genuinely presented before consent, whether the cooling-off period actually works, what the app collects from the phone, and whether recovery agents can reach data they should never see.
We audit the app, the platform and the data flows, and produce the report in the format the regulator expects.
What we go after
- Digital lending journey and consent flow review
- Key Fact Statement presentation and timing
- Cooling-off period implementation
- Mobile app permissions and data collection
- Borrower data storage, retention and sharing
- LSP and DLA contractual and technical controls
- Grievance redressal and nodal officer accessibility
- Recovery agent access controls
How we run it
- 01
Gap assessment
We measure you against the standard as it is actually audited, not as it reads on paper.
- 02
Remediation plan
Every gap gets an owner, an effort estimate and a date. You decide what lands this quarter.
- 03
Implement and evidence
We write the policy, build the control and collect the artefact that proves it is working.
- 04
Internal audit
A dry run under audit conditions, so nothing in the real one is a surprise.
- 05
Certify and maintain
We sit on your side of the table for the audit, then keep the evidence current between cycles.
What you receive
- System Audit Report in the prescribed format
- App permission and data collection assessment
- Consent and disclosure flow findings
- Remediation plan with regulatory deadlines
Who needs this
NBFCs, banks and fintech lenders operating digital lending platforms, and the lending service providers acting for them.
How long it takes
Four to eight weeks for the annual cycle.
Standards this satisfies
- RBI Digital Lending Directions
- DPDP Act
- CERT-In
Why it matters
Almost nobody starts a certification because they want one. It starts because a customer will not sign without it, a regulator has asked, or a deal is sitting still while procurement waits for evidence. The commercial driver is real and it is worth being honest that it, rather than security, is usually what pays for the programme.
The security benefit is real too, but it comes from a specific place: the discipline of having to evidence that a control operated over a period, rather than that it was configured once. That is the part that changes behaviour, and it is also the part organisations consistently underestimate.
Choose how you want this delivered
Most of the price difference between quotes comes down to this one choice, and it is rarely explained. Pick one to see what it covers, what it suits and what it costs you.
Gap assessment, then we work alongside your team through remediation, internal audit and the certification audit itself. Your people do the work and own the outcome, which is what makes the management system survive after we leave. This is what most organisations should choose.
Choose this when
- You have a team who can absorb the work alongside their day job
- You want the capability to remain in-house afterwards
- First certification where documentation is the main gap
Effort and cost
Moderate. The calendar is longer than a managed programme because the work competes with everyone's existing responsibilities.
Scope it yourself, before you call anyone
Answer a few questions and you get an indicative number, the working behind it and what your answers tell us. It runs in your browser, so nothing you type reaches us.
Which framework are you going for?
What we look for, and keep finding
These are the classes of problem this work exists to surface. Not every engagement finds all of them, but these are the ones that turn up often enough to be worth naming.
Controls that exist on paper only
The policy says quarterly access reviews. The evidence shows one, eighteen months ago, and it was not completed. This is the single most common audit finding across every framework.
Scope drawn too narrowly
A certificate covering a subset of the business that customers assume covers all of it. Auditors check the boundary; buyers rarely do. Getting scope right is the most consequential early decision.
Evidence that cannot be reproduced
A screenshot proves a control was configured on the day someone took it. A framework wants proof it operated throughout the period. Those are very different, and the gap only appears at the audit.
Exceptions with no expiry
Risk accepted once, recorded, and never revisited. Over a few years these accumulate into an undocumented second control framework nobody is managing.
Third parties outside the boundary
Processing carried out by a supplier who was assessed at onboarding and never since, while your obligation for their handling of your data continues regardless.
Who runs your engagement
A lead assessor who has sat on the other side of the table
Compliance work is led by an assessor who has taken organisations through certification, not by a consultant reading the standard for the first time with you. They know which findings a certification body will actually raise, which is a different list from what the standard technically says.
Questions we get asked
What usually fails?
Excessive app permissions and consent that is technically obtained but not meaningfully informed. Contacts and location access with no defensible purpose is the most common single finding.
Often scoped alongside
- CERT-In Cyber Security AuditCERT-In empanelled audit and certification for government and regulated entities.Read more
- ISO 27001 Audit & CertificationISMS design, implementation, internal audit and certification support end to end.Read more
- ISO 27017 Compliance AuditCloud-specific security controls for providers and customers.Read more
- ISO 27018 Compliance AuditProtection of personally identifiable information in public clouds.Read more
Ready to scope your dl-sar compliance audit?
Thirty minutes with a senior engineer, and you leave with a written scope and indicative effort.