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.
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.
Emerging Trends and Shifts in Microfinance
This study sought to understand the impact of the new regulations on the microfinance sector through the lens of different categories of stakeholders – customers, leadership at microfinance institutions (MFIs) and intermediating staff.
How Should the RBI Respond to the Microfinance Crisis?
Debt distress among microfinance borrowers is on the rise, sufficiently so that it may be characterised as a crisis for the sector. This is driven by factors across the supply- and demand-sides, as well as factors inherent in the nature of the credit cycle, where periodic booms and busts have been present throughout history. To address this, we propose two sets of recommendations for the regulator: a set of recommendations that can be initiated in the short-term and another set that can be initiated over the medium-term.
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
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.
Our Response to RBI’s Draft Omnibus Framework for recognising Self-Regulatory Organisations (SROs) for Regulated Entities (REs)
In this blogpost, we present our comments primarily to the former, but significantly implicating the latter. We include both frameworks since they cover similar subject matter – the creation of an SRO.
Moving towards harmonisation in financial regulation: Let’s start with capital
Higher capital adequacy norms locking up funds
