In this blog post, we present our responses to the Draft Enabling Framework for Regulatory Sandbox (hereafter the Draft Framework) in response to the call for comments from the stakeholders by the Reserve Bank of India (RBI).
Our response is accessible here. It is organised into five broad submissions raising some of our concerns with the Draft Framework.
- Clearer regulatory objectives must support the vision and design of the Regulatory Sandbox (RS).
- Restrictive eligibility criteria and entry conditions can risk defeating the objectives of the RS.
- The design of the RS must consider the extent of the RBI’s jurisdiction and cross-sectoral effects.
- The design and processes of the RS must embed mechanisms to enhance transparency in decision-making.
- The consumer protection elements of the RS must be stronger to ensure that the costs of innovation are not externalised on Indian consumers.
Our full response submitted to the RBI is available here.