In this blog post, we present our responses to the Discussion Paper on Guidelines for Payment Gateways and Payment Aggregators (hereafter the Discussion Paper) in response to the call for comments from the stakeholders by the Reserve Bank of India (RBI).
Our response is accessible here. Our comments are organised into five broad themes, which will seek to convey and substantiate the following feedback to the Discussion Paper.
- Clearer articulation of regulatory objectives is required to assess the proportionality of proposed regulation and to prevent duplication of regulatory efforts.
- Clarity is sought on the rationale guiding the distinction between payments gateways and payments aggregators.
- More detail on Option 1 and Option 2 of the proposed policy alternatives would enable a better comparison of their relative costs and benefits.
- The need to harmonise the proposed consumer grievance redress framework with existing consumer recourse mechanisms.
- We welcome the extension of IT security standards and urge for symmetric regulation of all digital financial activities to ensure uniform treatment of users’ data.
Our full response submitted to the RBI is available here.