Our comments to the Draft Guidance on Regulatory Expectations for Data Governance
Home > Publications > Consultation Responses
These are responses we write to documents that are put out by the government or the regulator in the public domain, often intended for public consultation – such as white papers or regulatory notifications or circulars or committee reports, etc.
Our comments to the Draft Guidance on Regulatory Expectations for Data Governance
The Draft Guidance proposes broad regulatory expectations for model risk management across the model lifecycle. It intends to strengthen governance, oversight, risk management and controls of Regulated Entities (REs) using models (including AI / ML models). In this response we present our comments to the Draft Guidance, through six recommendations
The Draft Amendments provide detailed guidance to relevant regulated entities (REs) on the loan recovery process, including mandatory certification for recovery agents, safeguards against harassment, grievance redressal mechanisms, and compensation for wrongful use of technology-based mechanisms.
In response to the public consultation, we argue that borrower over-indebtedness is a customer protection concern that must be explicitly recognised in the revised E&S Framework.
On 10 April 2026, the Reserve Bank of India released the “Draft – Reserve Bank of India (Non-Banking Financial Companies – Registration, Exemptions and Framework for Scale Based Regulation) Second Amendment Directions, 2026”. The Draft Amendments provide a new methodology to classify Non-Banking Financial Companies (NBFCs) in the Upper Layer of the scale-based regulatory framework, […]
In this response, we present our comments to the paper. We divide our comments into three sections.
In this response, we present four recommendations to the Draft Amendments.
In this response, we present our comments to the Draft Amendment Directions for ‘Advertising, Marketing and Sales of Financial Products and Services by Regulated Entities’ issued by the Reserve Bank of India on February 11, 2026.
In this document, we present our response to the policy document on DHRUVA (Digital Hub for Reference and Unique Virtual Address): The Digital Address DPI, hereafter referred to as the ‘policy document’, published by the Department of Posts in May 2025.
The Consultation Paper sets out the landscape of use cases of AI prevalent in the Indian Securities Market.
In all our research efforts, we strive to maintain an independent voice that speaks for the low-income household and household enterprises. Our ability to perform this function is significantly enhanced by our commitment to disseminate as a pure public good, all the intellectual capital that we create.