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By Asheeta Regidi and Aparajita Srivastava, Ikigai Law

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The Steering Board on Fintech Accompanying Issues (‘Committee’), set up by the Ministry of Finance, afresh issued its address (‘Report’)[1], in which it takes banal of developments in the fintech space, globally and in India. It makes 45 recommendations to accredit fintech, decidedly in analytical sectors of the economy, and to advance ‘ease of accomplishing business’ in India. Its focus areas accommodate removing the alterity amid coffer and non-bank players, acknowledging Micro, Baby and Medium Enterprises (‘MSMEs’) and the agronomical breadth to advance cyberbanking inclusion, acknowledging the role of abstracts in lending and enabling digitisation of key processes. Accession in the cyberbanking breadth through accessible data, agenda KYC, inter-regulatory cooperation, sandboxes, etc., are added key recommendations.

This commodity outlines the key recommendations put alternating by the Committee, and concludes with a agenda of antecedent industry reactions to the Report:

Removing abominable barriers amid coffer and non-bank players

A cogent advocacy of the Address is to ensure a akin arena acreage amid coffer and non-bank players, so as to enhance accession and antagonism and acquiesce agenda payments to ability their abounding potential[2].

First, it suggests acute the National Payments Corporation of India (‘NPCI’) to accommodate non-discriminatory admission to its acquittal basement to fintech firms and added cyberbanking firms, who are not currently shareholders in the NPCI. Accustomed the cartel of banks in the architecture of the NPCI, this claim of non-discrimination suggests a cogent about-face in the role of the NPCI. The Board abutting suggests that the Reserve Coffer of India (‘RBI’) and the proposed Acquittal and Settlement Systems Board abide demography agnate accomplish appear such calibrated liberalisation. This proposed adequation promises change in the fintech landscape, accepting active tech players to action new agency of activity cashless and accompany in accession in agency that traditional, bounden banks can’t.

MSME abutment via TReDS-GSTN integration

Next, the Address is focussed on lending abutment to MSMEs. A key advancement actuality is to absorb the Barter Receivables Discounting Arrangement (‘TReDS’), which facilitates the costs of MSMEs by accepting them to advertise their trades receivables to corporates, with the Goods and Casework Tax Network (‘GSTN’). This TReDS-GSTN integration, which, for instance, helps analyze counterfeit invoices, can anatomy the courage of a trusted antithesis infrastructure. This in turn, can anatomy the base for a flow-based lending arrangement for MSMEs by banks and Non-Banking Cyberbanking Companies (‘NBFCs’) [3]. The Committee, in fact, additionally recommends testing block-chain based solutions in barter accounts for MSMEs, to abolish inefficiencies in the accumulation alternation and lower risks[4].

Further recommendations actuality accommodate the conception of an accessible appliance programming interface (‘API’) – MSME stack, based on TReDS abstracts authentic by GSTN, for use by fintech companies[5], and conception of an India MSME assemblage which analogously facilitates barter financing, flow-based lending, allowance and bill factoring via abstracts pulled through APIs[6]. The Board additionally recommends that the RBI affair guidelines for banknote flow-based costs of MSMEs based on the TReDS-GSTN integration[7].

Reforming P2P Lending for a exchange archetypal of debt financing

A accompanying advancement to abutment costs MSMEs, households and individuals, is to ameliorate the accepted P2P lending archetypal to actualize a exchange archetypal of debt financing. This allows borer into assertive absolute appearance of the accepted and beginning P2P archetypal in India, for instance, that it involves a advanced ambit of abeyant lenders including not aloof banks but additionally non-banks, savers and others. The analysis of restrictions on acknowledgment banned in the accepted model, and options like accepting the Micro Units Development & Refinance Agency (‘MUDRA’) to fund/co-fund MSMEs via this archetypal are additionally suggested[8].

Supporting credit/insurance articles for the agronomical sector

A second, cogent breadth of focus of the Address is on leveraging fintech to abutment credit/ allowance articles for the agronomical sector. A key aspect of this is to adduce and accomplish bigger affection abstracts accessible to banks, fintech companies, and added lending agencies and insuring companies. This will advice in move abroad from collateral-based lending to data-based lending.

For bigger affection data, the address recommends borer into bombinate and alien analysis technology[9] and the digitisation of acreage records[10] to accumulate authentic abstracts on self-reported agriculture patterns, mortgages, encumbrances, acreage ownership, etc. Accustomed that coffer acclaim in the agronomical breadth is abundantly based on acreage ownership, such abstracts is essential. To this end, the Board additionally recommends the conception of a National Agenda Lands Annal Mission, with real-time API based admission to cyberbanking annual providers[11].

To added addition acclaim scoring as a agency of costs the poor and unbanked, the Board additionally suggests laying bottomward a formal, accord based apparatus accepting this[12]. As added sources of data, the Board additionally recommends the conception of an India Agri Stack, accepting accessible API admission to abstracts like acreage buying data, a farmer’s borrowing history, etc., to lenders[13].

KYC ameliorate and customer protection

In a analytical footfall appear enabling low amount KYC, the Board takes appropriate agenda of the accompanying issues that accept arisen in the fintech sector, due to the Supreme Court’s accommodation in the Aadhaar case[14]. By putting a stop to e-KYC or relying on the Aadhaar database in any way for KYC, advantages such as decidedly lower costs, greater ability and added accessibility for barter were lost.

The Committee, thus, aboriginal recommends exploring addition KYC models, such as e-Sign, non contiguous boarding, use of abstracts in the Digi Locker as able-bodied as video-based KYC[15]. The Board alone recommends that wet signatures be done abroad with in affiliation to assertive acknowledged processes (discussed below[16]). Extending this for KYC as able-bodied would be a analytical footfall appear enabling agenda on-boarding and acid costs.

In adjustment to added abate costs, the Board additionally suggests enabling the Central KYC (‘C-KYC’) anthology to booty off, such as via befitting upload of KYC abstracts chargeless and download accountable based on the user pays principle[17], and by allotment a borderline for authoritative the C-KYC anthology operational[18].

The Board is additionally focused on customer protection, advising that a acknowledged framework for this be in place, befitting in apperception issues like low agenda articulacy ante and benightedness of risks[19].

Open APIs, Accessible abstracts and Accessible banking

A ample focus of the Address is to accredit open, real-time and according admission to data. The Board appropriately suggests that accessible and according admission APIs of accordant datasets be created, such that fintech solutions can be congenital application them. Abstracts actuality charge be anonymized or included with consent[20].

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An absorbing advocacy which borrows from the European abstraction of accessible cyberbanking is that cyberbanking breadth regulators abstraction the abeyant of accessible abstracts access, to accredit bigger antagonism in cyberbanking services[21]. The Board recommends that accessible cyberbanking appear with, for example, aperture up alone acclaim applications (referral pools) with banks, accessible on a consent-basis to a aloof exchange of alternating lenders[22]. Similarly, it suggests that the RBI accessible up coffer abstracts accessible to fintech firms this way[23].

To acquiesce the administration of abstracts generated by government agencies as well, the Board additionally recommends that the National Abstracts Administration and Accessibility Policy should accept added acceptance, authoritative way for the administration of this abstracts in real-time, via accessible APIs[24].

In accession to accessible banking, the Board is additionally agog on basic banking, and recommends that its adequacy in the Indian book be explored[25].

Recommendations for activity paperless

To accord fintech a boost, it additionally suggests that authoritative changes be alien to abandon cyberbanking instruments[26], such as those for anchored deposits, baby accumulation certificates, absolute gold bonds, and so on. It analogously additionally suggests that amendments be alien to acquiesce paperless acknowledged alternatives for all acknowledged processes accepting a address on cyberbanking services, such as acceptance alternatives to wet signatures on concrete accommodation agreements for filing of accommodation accretion apparel in courts[27]. It additionally recommends accepting agenda alternatives for power-of-attorneys, assurance deeds, wills, cheques, etc.

Regulatory overhauls to abutment avant-garde and amalgam business models

As amalgam models emerge, acceptable regulations and divides of authoritative ascendancy charge a relook. To this end, the Board recommends that in accession to alone fintech initiatives and all-embracing collaboration, inter-regulatory allocation via inter-regulatory groups be established. The Inter-Regulatory Technical Group (IRTG) set up beneath the Cyberbanking Stability and Development Council Sub-Committee is appropriate as the appointment for such allocation for amalgam innovations[28]. Interestingly, the Board additionally suggests that in accession to alone authoritative sandboxes, an inter-regulatory head is essential[29].

Further, the Board recommends acceptance new business models[30]. In particular, it addendum restrictions on avant-garde business models on annual of acceptable laws. Examples are the barring of accomplishment from advertisements on web aggregator platforms in the allowance sector, or the bar on cyberbanking annual companies from outsourcing activities to fintech companies in the allowance sector[31].

Other Recommendations

Other recommendations include, broadly, creating aggressive neutrality amid entities accouterment agnate services[32], introducing admiring prudential norms[33], and auspicious the use of fintech for cybersecurity, artifice ascendancy and money laundering[34]. Addition advocacy is to analysis the authoritative arrangement for prepaid acquittal instruments (‘PPIs’), such as accretion the antithesis banned and liberalising its use with non-monetary limits[35].

The advantages of bogus intelligence, cerebral analytics and apparatus acquirements in back-end processes of PSU banks, such as in accident administration and artifice control, are additionally to be explored[36], as are the uses of Regulation Technology (RegTech)[37] and Supervisory Tech (SupTech)[38].

Industry Reactions to the Report

Concluding with a attending at industry reactions, the antecedent acknowledgment has abundantly been acutely positive. One affair acicular out by CUTS All-embracing is that the report, while authoritative abounding absolute recommendations, does not abundantly analyze the roadblocks that can appear in their implementation[39].

The cryptocurrency industry has acclaimed that the Report, interestingly, takes agenda of the use of cryptocurrencies and Antecedent Coin Offerings internationally, although it refrains from authoritative any recommendations at this stage. This may conceivably be on annual of the advancing action on the issue, but the abridgement of any abrogating statements either is actuality beheld as a absolute assurance and an accepting of the ‘revolutionary potential’ of cryptocurrencies[40].

Lending platforms like Faircent are seeing the recommendations on P2P lending and MSME abutment as absolute accomplish accouterment abundant bare stimuli to this sector. These recommendations are actuality apparent to potentially arch the addition acclaim gap and accredit P2P lending platforms to mobilise abandoned funds through bargain restrictions[41]. The abeyant of the TReDS-GSTN affiliation is addition point of absorption for fintech companies in the lending space[42].

For fintech companies in the payments space, the recommendations on accessible data, accessible access, and basic cyberbanking are actuality beheld positively. The recommendations on PPIs, naturally, are addition agency that acquittal companies are attractive advanced to[43].

Overall the recommendations of the Committee, accustomed the accession it proposes for fintech, has been well-received by the fintech industry.


[1] Issued September, 2019, Address of the Steering Board on Fintech Accompanying Issues, 2019, Department of Economic Affairs, Ministry of Finance, accessible at of the Steering Board on Fintech.pdf

[2] Advocacy No. 1.6.1, Ibid.: Removing abominable authoritative barriers in the agenda payments basement sector

[3] Advocacy No. 1.6.4, Ibid.: Flow-based lending for MSMEs

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[4] Advocacy No. 2.4.3, Ibid.: Public breadth block chain-based barter finance

[5] Advocacy No. 1.6.4, Ibid.: Flow-based lending for MSMEs

[6] Advocacy No. 2.4.7, Ibid.: Accessible APIs

[7] Advocacy No. 1.6.4, Ibid.: Flow-based lending for MSMEs

[8] Advocacy No. 1.6.5, Ibid.: Reforming P2P markets and creating a exchange archetypal for debt financing

[9] Advocacy No. 2.4.4, Ibid.: Alien Analysis & Bombinate Tech for Acclaim & Allowance

[10] Section 2.2.2, Ibid.: Digitisation of acreage records, at Page 55-56.

[11] Advocacy No. 2.4.5, Ibid.: Digitisation of Acreage Records

[12] Advocacy No. 1.6.10, Ibid.: Application anarchistic abstracts sources for bigger acclaim scoring and accretion admission to credit

[13] Advocacy No. 2.4.7, Ibid.: Accessible APIs

[14]K.S. Puttaswamy vs Union of India, W.P.(Civil) No. 494 of 2012, accessible at

[15] Advocacy No. 1.6.9, Ibid.: Reformed KYC action in the ablaze of the contempo Supreme Court judgement on Aadhaar

[16] Advocacy No. 2.4.6, Ibid.: Re-engineering Acknowledged Processes for the Agenda world, See Para beneath on Recommendations for activity paperless

[17] Advocacy No. 2.4.14, Ibid.: Eliminating costs of on-boarding KYC abstracts on eKYC Depository

[18] Advocacy No. 2.4.15, Ibid.: Mandatory use of C-KYC Registry

[19] Advocacy No. 2.4.16, Ibid.: Customer Aegis framework

[20] Advocacy No. 2.4.7, Ibid.: Accessible APIs

[21] Advocacy No, 2.4.13, Ibid.: Accessible Abstracts for acceptable competition

[22] Ibid.

[23] Ibid.

[24] Advocacy No. 2.4.8, Ibid.: Expanding Accessible Government Data

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[25] Advocacy No. 1.6.6, Ibid.: Basic banking

[26] Advocacy No. 1.6.7, Ibid.: Dematerialisation of cyberbanking instruments

[27] Advocacy No. 2.4.6, Ibid.: Re-engineering Acknowledged Processes for the Agenda world

[28] Advocacy No. 4.6.4, Ibid.: Inter-regulatory allocation on fintech

[29] Section 2.3.3, Ibid.: Authoritative sandboxes, at Page 69.

[30] Advocacy No. 2.4.9, Ibid.: Abutment for new business models

[31] Ibid.

[32] Advocacy No. 2.4.10, Ibid.: Aggressive ‘neutrality’ in regulation

[33] Advocacy No. 2.4.12, Ibid.: Planning for aerial appulse fintech scenario

[34] Advocacy 1.6.2, Ibid.: Fintech for cybersecurity

[35] Advocacy No. 1.6.8, Ibid.: Ameliorate of Pre-paid instruments (PPI) system

[36] Advocacy No. 2.4.2, Ibid.: Bogus Intelligence for back-end processes

[37] Advocacy No. 2.4.18, Ibid.: Regulation Technology (RegTech)

[38] Advocacy No. 2.4.19, Ibid.: Supervisory Technology (SupTech) for Regulators

[39] Quote by Pradeep S Mehta, Secretary General, CUTS International, in Media Commodity by K.R. Srivats: Console on fintech bats for ‘marketplace model’ of debt financing, The Hindu Business Line, anachronous September 4th, 2019, accessible at

[40] Quote by Sumit Gupta, CEO CoinCDX, in Blogpost by Vikrant Mansera: CoinDCX on India’s Fintech Address – India stands bullish on Blockchain and Crypto, Website of CoinDCX, anachronous September 4th, 2019, accessible at; See additionally Quote by Aanchal Thakur, Managing Partner DayOrg Consulting Group, in commodity by Naimish Sanghvi: DEA Steering Board Address says Blockchain and ICOs are revolutionising Fintech Landscape, CoinCrunch, anachronous September 3rd, 2019, accessible at

[41] Media Commodity by Rajat Gandhi, CEO, Faircent: Why fintech console believes P2P platforms can affluence acclaim supply, The Economic Times, anachronous September 5th, 2019, accessible at

[42] LinkedIn Post by Amit Tyagi, Chief Business Officer, Unimoni, LinkedIn, appear in September 2019, accessible at

[43] Ibid.


This commodity has been authored by Asheeta Regidi with inputs from Aparajita Srivastava. Regidi is an absolute adviser and Srivastava is a Senior Associate (Regulatory & Policy), Ikigai Law.

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