RBI Co-Lending Directions 2025: Bank Partners Can No Longer Cherry-Pick Loans
For co-lending arrangements made from 1 January 2026, RBI's Co-Lending Directions 2025 require partners to commit upfront to every loan. The bank is now evaluating the NBFC's underwriting method, and for batteries that method is often thin.
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In co-lending, an NBFC's bank partner used to review each loan and decide yes or no. Under RBI's new rules, it says yes once, upfront.
For co-lending arrangements made from 1 January 2026, RBI's Co-Lending Directions, 2025 require three things. Picking loans one by one is now a loan transfer under separate RBI rules, not co-lending.
What the 2025 Directions require
- Commitment, irrevocable: the partner commits upfront to take its share of every loan originated.
- Retention, at least 10% each: bank and NBFC both keep a minimum 10% of every loan on their books. Earlier, only the NBFC had to keep 20%.
- Speed, booked in 15 days: each lender's share must be in its books within 15 days of disbursal.
Two frameworks, the same loan
- Before (2020 circular), loan by loan: the bank accepted or rejected each loan; only the NBFC had to keep 20%; priority-sector loans only.
- Now (2025 Directions), committed upfront: the bank takes its share of every loan; both lenders keep 10% or more; all lending, one blended rate.
Our reading, not RBI's wording: the bank is no longer evaluating your loans. It is evaluating your underwriting method.
The gap in most green books: solar is easy to check, the battery isn't
In a C&I solar + storage loan file, solar yield, tariff savings and degradation follow standard, checkable methods, so the lender checks them. For the battery, most NBFCs still rely on the EPC's own spreadsheet. Battery savings are harder to check because of:
- Load shape: when the site uses power sets what the battery earns.
- Diesel and tariffs: DG hours and time-of-day rates are rarely evidenced.
- Design choices: the same plant can carry very different batteries, and loans.
Under co-lending, a gap in the method is a gap in every loan the partner commits to.
Closing the gap: write the battery into the method
The fix is a one-page storage assessment the bank partner can read, built from the bills and EPC proposal already in the file:
- Range: savings as expected and conservative cases, not one number.
- Source: savings from solar self-use, time-of-day shift and diesel, shown apart.
- Fade: battery capacity loss applied year by year in the cashflow.
- Cover: payback versus tenor, and whether the conservative case still covers the EMI.
For green co-lending programmes, how the storage assessment is documented for the bank partner is now part of the credit method itself.
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