Comments on the RBI Draft Master Directions on Issuance and Operation of Prepaid Payment Instruments in India
The Reserve Bank of India (RBI) released the Master Directions on Issuance and Operation of Pre-paid Payment Instruments (PPIs) in India (Draft Circular) on 20 March 2017.
Comments dated 20 March 2017 on the draft of the “Information Technology (Security of Prepaid Payment Instruments) Rules 2017” dated 8 March 2017 (Draft Rules) released by the Ministry of Electronics and Information Technology, Government of India (MeitY)
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.
Comments on the Ministry of Electronics & Information Technology’s Draft Rules for Security of Prepaid Payment Instruments
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.
