Nasscom-DSCI Submission on RBI Master Directions on PPIs

The Reserve Bank of India(RBI) recently released Master Directions on Issuance and Operation of Prepaid Payment Instruments(PPIs) in India and sought comments and suggestions from the stakeholders to finalize the draft. DSCI-NASSCOM analyzed the draft, consulted member organizations operating in this space and accordingly have prepared attached inputs that is submitted to RBI for further action. The inputs have been provided at principal level on the overall approach this framework should take, followed by section specific comments.

PPIs have been instrumental in contributing to the ‘less cash’ vision of the Government of India. They have emerged as a viable alternative to cash, especially post-demonetization. In the interest of the government’s less-cash vision, regulation should attempt to retain the advantages offered by PPIs such as ease of use, ease of on-boarding and customer acquisition, while also ensuring safety, security and reliability of transactions. For Digital India to succeed, cyber security and data protection have to be addressed. Standardized and streamlined security related requirements, than multiple regulatory requirements originating from different sources, will help raise focus on security implementation. In the submission, NASSCOM & DSCI, among other things, highlight the progressive and landmark Watal committee report on Digital payments which came out in December 2016. We also highlight the importance of enacting a comprehensive Privacy Law in the country.