Comments to Draft Reserve Bank of India (Commercial Banks – Responsible Business Conduct) Amendment Directions, 2026, dated 6 March 2026

In this response, we present four recommendations to the Draft Amendments.
Comments to Draft Reserve Bank of India (Commercial Banks – Responsible Business Conduct) Amendment Directions, 2026, dated 11 February 2026

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.
Credit Demand of FPOs – A Credit Market Estimation Exercise

This article aims to provide a preliminary estimate of the credit requirements of FPOs, drawing on the experience of professionals who have been closely associated with FPOs for several years in their development and operations.
Towards Customer-Centric KYC: RBI’s 2025 Amendments from a Financial Inclusion Lens

In this blog post, we analyse the changes in the direction and weigh them through the lens of customer protection and long-term sustainability. We also offer suggestions on streamlining the KYC updation (re-KYC) exercise without adding to systemic risks.
Our Observations on the Draft Banning of Unregulated Lending Activities (BULA) Act by the Ministry of Finance (MoF), GoI

On 13 December 2024, the Ministry of Finance, Government of India (MoF) released the draft Banning of Unregulated Lending Activities (BULA) Act. This aligns with recommendations made in the Report of the Working Group on Digital Lending.
Responsible AI means good business for all

When AI-driven decisions are fair, respect privacy and are not opaque, they foster customer confidence
Need a more flexible AePS environment

While the Aadhaar Enabled Payment System (AePS) has emerged as the foundational technology enabling cash-in cash-out (CICO) across the country, efforts by bad actors to defraud banking customers through it continue to be a pressing concern
Could we be doing better with consent?

This blog presents a self-assessment checklist targeted at UI/UX designers and AA product managers, enabling them to surface gaps in the design of their consent artefacts especially in relation to the vulnerable customer.
SEBI’s proposed changes can spruce up investment advisory regulations

The new proposals can significantly increase the number of RIAs by relaxing the requirement of having a Master’s degree and prior work experience and by lowering net-worth requirements.
Our response to the RBI’s Draft framework for recognising Self-Regulatory Organisations (SRO) for FinTech Sector
Our response covers two themes:
Leading from a customer protection perspective, our comments emphasise the need for the prospective SRO to have duties towards the customers, at par with responsibilities towards the regulator.