Independent Research and Policy Advocacy

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 Work

November 1, 2019 | Dvara Research

Our response to the Ministry of Labour on social security code.

By Anupama Kumar
September 17, 2019 | Dvara Research

In this Response, we present our comments on the RBI’s Discussion Paper on the Guidelines for Payment Gateways (PG) and Payment Aggregators (PA) in response to the call for comments from stakeholders (Reserve Bank of India, 2019c). Our comments are organised into five broad themes...

By Beni Chugh, Madhu Srinivas, Anubhutie Singh, Sarah Stanley
May 10, 2019 | Dvara Research

Recommendations that financial sector regulators can consider applying on regulated financial services providers in order to improve outcomes for households and enterprises.

May 8, 2019 | Dvara Research

Response to the Reserve Bank of India on the Draft Enabling Framework for Regulatory Sandbox

October 10, 2018 | Dvara Research

In this document, we present our comments on the draft Personal Data Protection Bill 2018 (hereafter “the draft Bill”) in response to the call for comments from the public by MEITy (Ministry of Electronics and Information Technology, 2018)

By The Future Of Finance Initiative
October 10, 2018 | Dvara Research

Comments to the Ministry of Electronics and Information Technology (MEITy) on the draft Personal Data Protection Bill 2018

By The Future Of Finance Initiative
February 7, 2018 | Dvara Research

In this document, we present our responses to the public consultation on the White Paper which is based on our broader approach on data protection. This approach looks past a consent-led approach to data protection, and seeks to embed a bundle of rights for all individuals with respect to their personally identifiable data that apply even where consent has been validly obtained for data collection

By The Future Of Finance Initiative
April 26, 2017 | Dvara Research

The Future of Finance Initiative (FFI) is housed within the IFMR Finance Foundation (IFF) and aims to promote policy and regulatory strategies that protect individuals accessing finance given the sweeping changes that are reshaping retail financial services in India. Our vision is for every individual to have universal access to suitable financial services using a range of channels that enable them to transact securely and confidently.

By The Future Of Finance Initiative
March 27, 2017 | Dvara Research

Our comments in response to the Draft Rules are presented in two sections below. In the first section titled “I. Overarching Comments”, we raise two broad points on (1) extending the data protection principles consistently to avoid regulatory gaps, and (2) the need for regulatory coordination to avoid dual regulation, mitigate potential capacity constraints for MeitY and any adverse impact on the ease of doing business for pre-paid instrument (PPI) issuers. In the second section titled “II.

By The Future Of Finance Initiative
March 27, 2017 | Dvara Research

On 8 March 2017, the Ministry of Electronics & Information Technology (MeitY) released a set of draft rules for security of prepaid payment instruments (Draft Rules), inviting comments by 20 March 2017.