WhatsApp for lenders in India: what you can and cannot send

Compliance review required before publishing.

WhatsApp is now part of how many Indian borrowers expect to hear from their lender. It is also a channel with its own rules, set by Meta, layered on top of the rules you already follow as a regulated lender. This guide sets out the WhatsApp rules that matter most to lending teams, in plain language, and points to the source for each one. It is not legal advice. Your compliance team decides how these rules apply to your business.

Start with permission

WhatsApp's Business Messaging Policy says a business may contact people on WhatsApp only if they have given the business their mobile number and agreed to be contacted on WhatsApp. Meta's developer guidance on opt-in adds that the opt-in should make clear that the person is agreeing to receive messages from your business on WhatsApp, and should name your business.

For a lender, that usually means three questions:

1. Where did the opt-in happen? A loan application form, a mobile app screen, a branch form or a WhatsApp conversation the customer started are all common sources.
2. What did the customer see? Keep the exact wording of the consent text, or a reference to the version of the form they used.
3. When did it happen? The date and time, so you can show the opt-in came before the first message.

Keep those three answers for every contact. If a customer complains, or an auditor asks how you got permission, they are what you will need.

Permission also has to be easy to withdraw. The policy requires businesses to respect a person's request to stop messages. In practice, customers say "STOP", "unsubscribe", "band karo" or "don't message me". Your process should recognise the common phrases in the languages your customers use, stop marketing messages at once and confirm that you have done so.

Know the three template categories

When you message a customer who has not written to you in the last 24 hours, you must use a message template that Meta has approved. Meta groups templates into three categories:

• Utility: messages about a specific transaction or account the customer already has, such as an EMI due date, a disbursal confirmation or a change to their loan.
• Marketing: anything that promotes a product, offer or service, including top-up loans, pre-approved offers and festival campaigns.
• Authentication: one-time passcodes to verify a customer.

The category matters for three reasons. Meta's rates differ by category. Meta reviews the category you choose and may change it if the content does not fit. And customers react differently: a marketing message sent to someone who did not expect it is a common reason for blocks and reports, which affect your number's quality rating.

A useful test for lending teams: if the message would still make sense to a customer who never wanted to hear about new products, it is probably utility. If it tries to sell something, even gently, it is marketing. "Your EMI of ₹12,450 is due on 05 Nov" is utility. "You are eligible for a top-up of up to ₹2 lakh" is marketing, and should go only to customers who agreed to receive offers.

Respect the 24-hour customer service window

When a customer messages you, a 24-hour customer service window opens. Inside it, you can reply with free-form messages: plain text, documents, images and interactive buttons, without a template. Each new message from the customer restarts the window. Once it closes, you can only send an approved template.

This shapes how lending teams work:

• Agents must answer quickly. If a borrower asks a question at 6 pm and your team answers the next evening, the window may have closed, and the agent needs a template to restart the chat.
• Follow-ups need templates. A "Did you manage to pay?" message two days later is a template message, not a free-form one.
• Your tools should enforce it. Agents should not have to calculate the window by hand. The platform should show it and block free-form messages when it has closed.

Write templates that survive review

Meta rejects templates for reasons that are easy to avoid once you know them. For lenders, the most common problems we see in drafts are:

• Variables at the very start or end of the message, or two variables next to each other, which make the template hard for Meta to review.
• Sample values that are missing or only repeat the placeholder.
• Promotional wording inside a template submitted as utility.
• Shortened links that hide where they lead.
• Wording that promises outcomes, such as "pre-approved" or "guaranteed", which can also raise questions from your own compliance team.
• Collections language that sounds like a threat.

Write the customer-facing text first, then add variables. Read it aloud. If it would embarrass you on a regulator's desk, rewrite it.

Collections: timing and tone

Collections messages are where WhatsApp rules and lending rules meet. The Reserve Bank of India's circular of 12 August 2022 on recovery agents says lenders and their agents must not call borrowers before 8:00 am or after 7:00 pm for recovery of overdue loans, and must not use intimidation or harassment of any kind. The circular speaks of calls. Many lenders apply the same hours and the same standard of tone to written messages as a matter of policy. Ask your compliance team what your policy is, then set it in your messaging tool so that it does not depend on each agent remembering.

Tone matters as much as timing. A good collections message:

• States the facts: amount, loan reference and date.
• Offers a clear next step: pay now, ask for more time or talk to a person.
• Never threatens, shames or mentions consequences that are not real.
• Goes to the borrower only, never to references or family.

When a customer replies, a trained person should take over quickly, with the history in front of them.

Protect your number's quality

Meta gives every business phone number a quality rating based on how people respond to your messages, especially blocks and reports. A falling rating can limit how many people you can message and, in serious cases, lead to restrictions on the number. Meta's documentation on messaging limits explains the tiers and how they change.

For lenders, the practical protections are simple:

• Message only people who opted in, and only about what they opted in to.
• Exclude anyone who has opted out, every time, immediately before sending.
• Pace large sends instead of sending everything at once.
• Watch the quality rating, and pause campaigns when it drops.

A checklist for your next send

Before any WhatsApp send to borrowers, check that:

• [ ] Every recipient has a recorded opt-in with source, wording and time.
• [ ] Opted-out numbers are excluded at the moment of sending.
• [ ] The template category is right, and it was approved by Meta.
• [ ] The send window matches your collections or communications policy.
• [ ] A second person has approved the send.
• [ ] Your number's quality rating is healthy.
• [ ] A team is ready to answer replies within the 24-hour window.

How Senderr helps

Senderr was built for these rules. It keeps a consent ledger for every contact, recognises STOP and Hindi and Hinglish opt-out replies, checks consent and suppression before each message, enforces the 24-hour window in the inbox, flags risky template wording before submission, and requires maker-checker approval for campaigns if you switch it on. Campaigns pause on their own if your number's quality rating drops.

Request access to see how your journeys would look on Senderr.