In this Response, we present our comments on the RBI’s Draft Framework for Authorisation of a Pan-India New Umbrella Entity (NUE) for Retail Payment Systems (Reserve Bank of India, 2020) (hereafter ‘Draft Framework’).
Our comments are organised into two sections.
Section I recognises five overarching concerns (summarised below), which will seek to convey and substantiate the following feedback to the Draft Framework.
1. Clearer regulatory objectives must guide the vision and design for NUE.
2. The definition and Scope of Activities need clearer articulation and greater alignment with regulatory objectives.
3. The Draft Framework must clarify if these regulations will apply to the NPCI, retrospectively.
4. The Draft Framework must incentivise interoperability to ensure competitiveness among NUE(s).
5. The Draft Framework needs to outline a robust consumer protection framework.
To read full report, click here
