Each model bills at a different stage
An applicant moves from click to application, qualified application, approval and disbursal. A pricing model fixes where the acquisition partner is paid, so the partner carries the cost of every stage before that point.
- CPL, cost per lead: a completed enquiry with contact details.
- CPA, cost per acquisition (some partners say cost per action): an application that meets agreed criteria, or another agreed outcome such as approval.
- CPD, cost per disbursal: a loan disbursed to the borrower.
| Stage | CPL | CPA | CPD |
|---|---|---|---|
Click Arrives from a source. | Not billed | Not billed | Not billed |
Application Enquiry with contact details. | Billable event | Not billed | Not billed |
Qualified application Meets the agreed criteria. | Open to reversal | Billable event | Not billed |
Approval The lender decides. CPA can bill here where agreed. | Open to reversal | Open to reversal | Not billed |
Disbursal Loan paid out to the borrower. | Open to reversal | Open to reversal | Billable event |
Validation window The lender can still reverse or adjust a billed event. | Open to reversal | Open to reversal | Open to reversal |
| Model | Who carries conversion risk | What the lender reports back |
|---|---|---|
| CPL | The lender carries almost all of it: applicant quality, approval and disbursal. | Receipt of the lead, and any duplicates or invalid contact data. |
| CPA | Shared. The partner is not paid for applications that miss the criteria or fail fraud checks; the lender makes the credit decision. | Application status, and the agreed outcome when it is reached. |
| CPD | Mostly the acquisition partner, including the lender's approval rate and policy changes. | Disbursal and its date, plus a code from the agreed rejection list; a credit decline is one generic code, with no score or bureau detail. |
Illustrative split. Exact events, criteria and fields are agreed per lender.
The later the billable event, the more conversion risk the partner carries and the more the lender's reporting matters, because the partner cannot see approval or disbursal on its own. A partner paid on disbursal prices in the lender's approval rate and any policy change, so agree in writing how criteria changes are notified. CPA suits a lender that wants volume it can measure early, CPD one that pays only for funded loans.
In India, RBI's digital lending rules for NBFCs, in Chapter III of its Credit Facilities Directions, 2025, generally require disbursal into the borrower's own bank account and bar a third party from controlling the flow of funds between borrower and lender. A partner therefore stays outside the money flow, so a CPD invoice rests on the lender's records. The India market page covers the rules.
A billable event needs a written definition
Whatever the model, the contract should name the billable event in terms both systems can record.
- The status that bills, such as an application passing agreed criteria or a loan marked disbursed.
- The click ID that ties the event to the originating click, and the sub-id that ties it to the source.
- Which timestamp counts, and in which time zone.
- How a repeat application from the same person is treated.
- The market and product the event belongs to.
Validation windows decide when an event becomes final
A validation window is the period after the billable event in which the lender can still reverse or adjust it. Awin's e-commerce affiliate documentation says each programme has its own validation period and only pending commissions can be amended.
In India, a reversal or adjustment tied to repayment, such as a refund when the first instalment is missed, can count as an implicit default loss guarantee, which RBI allows only with an LSP or another lender engaged as one and caps at 5% of the amount disbursed. Have counsel read any such term; see India.
A lender may learn of a problem only after the event. Agree how long the window runs, what the lender must send before it ends, whether a reversal reported after it closes still applies, and what happens if no status arrives. Awin auto-approves commissions left unreviewed, so choose the default for silence on purpose: approve, reject or escalate.
Rejections should come back with a reason
A rejection with no reason cannot be acted on, so a lending contract needs a short list of reason codes.
- Outside the agreed criteria, such as age, area or income band.
- Duplicate of an earlier application from the same person.
- Identity or fraud flag raised by the lender.
- Click ID missing, altered or not matched to a delivered applicant.
Send back the least the invoice needs: the click ID, a status, a reason code and the event time. Names, contact details, identity documents and bureau data do not need to travel back. Even this set can identify an applicant to a partner that links the click ID to a person, so what a lender may send depends on its notice, the borrower's consent and local law. In India, for instance, RBI's digital lending rules require an NBFC to take the borrower's explicit consent before sharing personal information with a third party, unless a statute or regulation requires the sharing.
Coded rejections settle the invoice. Counted by source, they also show where to tighten screening or which source to cut back, as in lead quality by source. Any use tied to a person, such as recognising a returning applicant, depends on the lender's notice and the borrower's consent.
Caps limit volume per market and product
A cap limits volume in a period, usually per day or month, counted in clicks, applications or billable outcomes. In Everflow's tracking platform, a hard cap stops tracking new clicks and marks them as invalid clicks. A conversion that completes after the cap closes, from a click made while it was open, is recorded as pending with the reason 'Over Caps' for manual approval or rejection. Voluum's tracker sends new visitors to the cap's redirect offer and notes that the conversion count can still exceed the cap, since some visitors convert much later.
So a cap closes new delivery but does not erase outcomes in flight. Agree what happens to new applicants at the cap, and whether outcomes from earlier deliveries still bill.
Billing depends on the lender reporting the outcome
Under CPD, and under CPA when the agreed outcome comes after handoff, such as approval, the billable event happens on the lender's side after the applicant has left, so the lender has to report it. How that report travels is covered in the postback guide for referral setups and the API guide for direct ones.
Count one outcome per click ID or application reference and status, so a retried postback or webhook never bills twice.
CYBERTECH offers CPA or CPD against an agreed event
CYBERTECH is not a lender. It offers CPA on a qualified application or an agreed partner outcome, or CPD on a disbursed loan; the billable event is defined together with you before launch. You define the market, product criteria and capacity and keep the final credit decision; rules are agreed per market and product during onboarding.
Daily or monthly caps apply per market and product, and delivery throttles when a cap is reached. Referral and direct API setups are described under integration.
To scope the billable event, get in touch with these inputs:
- The market and product, and the criteria an applicant must meet.
- The daily or monthly capacity you want per market and product.
- The status that should bill, and how your system will report it.
- The validation window and the rejection reasons you expect to use.
No price list is published. Contract and regulatory points on this page are general information, not legal advice.
Related guides
- Implement a referral redirect and S2S postback for loan leadsHow to store redirect parameters, verify the signature, send outcome statuses and handle retries and duplicates.
- Loan leads reach you by referral or by direct APIReferral with a server-to-server postback and a direct API deliver the same screened applicants; this page helps you choose and walks through a launch.
- Measure loan lead quality by source, from approval to delinquencyHow a lender measures lead quality by source: approval, disbursal, first-payment default, 30+ DPD, fraud rate and cost per disbursed loan.
- Lending acquisition glossary, from CPA and CPD to DLG and DPDDefinitions of lending acquisition terms, from CPA, CPD and postbacks to NBFC, LSP, DLG, MFO and loan stacking, with links to the guides that go further.
Sources
- Reserve Bank of India: NBFC Credit Facilities Directions, 2025, Chapter III Digital Lending, paras 10 and 13 (2025, updated 2026)
- Awin: Understanding commission validation (published Mar 2026, updated Oct 2026)
- Everflow Helpdesk: How to manage caps (accessed Oct 2026)
- Voluum: Offer cap (accessed Oct 2026)