Independent Research and Policy Advocacy

Comments to the Reserve Bank of India on the Draft Framework for Authorisation of a PanIndia New Umbrella Entity (NUE) for Retail Payment Systems dated 10 February 2020

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.