Web Analytics

  • Law Asia
  • ABLJ
  • CBLJ
  • IBLJ
Register Login Subscribe
Resources
Awards galleryA-List lawyersLaw firm directory
Sections
NewsFeaturesPractice guidesBusiness law digestCorrespondentsExpert briefingIn-house agenda
Topics
Bankruptcy & insolvencyCapital marketsCompetition & antitrustDispute resolutionEmploymentESGHealthcare & life sciencesIntellectual propertyM&AReal estateTaxTMT
Law.asia home
Archive
.TV
Awards
CBLJ Forum•Beijing 2026
Events
Jobs
About us
Contact us
Follow Law.asia

Asia Business Law Journal
Asia Business Law Journal

    • LinkedIn
      Facebook
      Twitter
      Whatsapp
      Telegram
      Copy link

      SECTIONS

      • News
      • Features
      • Practice guides
      • Business law digest
      • Correspondents
      • Expert briefing
      • In-house agenda

      ABOUT US

      • Editorial board
      • Publisher & credits

      TOPICS

      • Bankruptcy & insolvency
      • Capital markets
      • Competition & antitrust
      • Dispute resolution
      • Employment
      • ESG
      • Healthcare & life sciences
      • Intellectual property
      • M&A
      • Real estate
      • Tax
      • TMT

      RESOURCES

      • Awards gallery
      • A-List lawyers
      • Law firm directory

      E-READER EDITION

      ARCHIVE
      LinkedIn
      Facebook
      Twitter
      Whatsapp
      Telegram
      Copy link
Asia Business Law Journal Asia Business Law Journal
  • Sections
    • News
    • Features
    • Practice guides
    • Business law digest
    • Correspondents
    • Expert briefing
    • In-house agenda
  • Topics
    • Bankruptcy & insolvency
    • Capital markets
    • Competition & antitrust
    • Dispute resolution
    • Employment
    • ESG
    • Healthcare & life sciences
    • Intellectual property
    • M&A
    • Real estate
    • Tax
    • TMT
  • Videos
  • Awards
  • Jobs
  • Subscribe
  • Law Asia
  • ABLJ
  • CBLJ
  • IBLJ
  • icon
    • Login
    • Register
  • Law Asia
  • ABLJ
  • CBLJ
  • IBLJ

Asia Business Law Journal
  • Sections
    • News
    • Features
    • Practice guides
    • Business law digest
    • Correspondents
    • Expert briefing
    • In-house agenda
  • Topics
    • Bankruptcy & insolvency
    • Capital markets
    • Competition & antitrust
    • Dispute resolution
    • Employment
    • ESG
    • Healthcare & life sciences
    • Intellectual property
    • M&A
    • Real estate
    • Tax
    • TMT
  • Videos
  • Awards
  • Jobs
  • Subscribe
  • icon
    • Login
    • Register
Home Cyril Amarchand Mangaldas Will AAs revolutionise India’s financial services?
  • Cyril Amarchand Mangaldas
  • Fintech
  • Tech law

Will AAs revolutionise India’s financial services?

By Anu Tiwari and Anindita Bhowmik, Cyril Amarchand Mangaldas
10 November 2021
0
2468
LinkedIn
Facebook
Twitter
Whatsapp
Telegram
Copy link

In accessing financial services or products, individuals are often required to share financial information stored with other entities. The lack of a centralised mechanism to access information makes the process time-consuming and often unreliable. Keeping this in mind, the inter-regulatory Financial Stability and Development Council introduced the concept of account aggregators (AAs) in 2015. AAs were conceptualised as entities that would securely share the financial information of users on a consent-based mechanism. Subsequently, the Reserve Bank of India (RBI) notified the Master Direction on Non-Banking Financial Company (NBFC) – AA, on 2 September 2016 (the AA master direction).

payment
Anu Tiwari
Partner
Cyril Amarchand Mangaldas

Under the master direction, AAs act as intermediaries that assist with the sharing of financial information among consumers and financial institutions. The AA network is built on three pillars: (1) financial information users (FIUs); (2) financial information providers (FIPs); and (3) the AAs themselves.

FIPs include institutions such as banks, insurance companies, pension funds, etc. FIUs include entities regulated by a financial sector regulator, and require consumer financial information to provide financial services. For instance, an NBFC that is an FIU may rely on certain financial information available with a bank or a mutual fund (an FIP) to assess the creditworthiness of a customer before issuing a loan.

Transfer of information from FIPs to FIUs has traditionally been paper-based. With paperless and secure transmission of information through the AA network, availing of financial services will become seamless. Faster data collection will mean more effective credit checks. It will also make the process of loan disbursement quicker and more data-driven, benefiting both new age and traditional lending channels. Small and medium-sized enterprise financing could see an uptick with ease of access to financial information, furthering financial inclusion in the country.

Anindita Bhowmik, Partners, Cyril Amarchand Mangaldas
Anindita Bhowmik
Partner
Cyril Amarchand Mangaldas

The transmission of financial information from an FIP to an FIU happens in an end-to-end encrypted manner, such that AAs cannot read the customer information themselves, making them “data blind”. Notably, this protects the interests of customers, as the AAs cannot sell customers’ financial information, or use it for related data analytics. The AA framework is founded on informed user consent, which is enabled by the Ministry of Electronics and Information Technology’s “consent artefact”. This consent artefact allows users granular control over their financial information by enabling them to customise their consent parameters in terms of the duration and purpose for which the information is shared, the frequency with which it can be accessed, and the data fields being shared. Users may revoke their consent at any point, allowing them complete control over the use of their financial information.

Enabling the AA ecosystem

Driving scale for the AA ecosystem requires interoperability and generic technical standards for all participants in the ecosystem. To this end, the RBI and the industry have undertaken second-stage initiatives that assist the implementation of the vision within the AA master direction.

The RBI’s wholly owned subsidiary, Reserve Bank Information Technology (ReBIT), has framed technical specifications for application programming interfaces that can be readily utilised by AAs and financial institutions to enable real-time aggregation functionality of financial information.

In 2019, DigiSahamati Foundation was set up as a not-for-profit company to be a self-organised collective of the AA ecosystem. The foundation aims to ensure that all participants in the ecosystem meet common privacy and security standards, while driving innovation and scale within the network. On 2 September 2021, the AA network went live for consumers across India. Speaking at the launch event, the RBI’s deputy governor remarked that AAs have the potential to strengthen the lending economy and transform digital lending by making it data-driven.

Currently, four NBFC AAs have received an operating licence under the AA master direction – CAMSFinServ, FinVu, OneMoney, and NeSL Asset Data Limited – with three entities receiving in-principal approval from the RBI – PhonePe, Yodlee and Perfios. Major banks in the country, including the State Bank of India, ICICI Bank, Kotak Mahindra Bank and Axis Bank, have joined the AA network as FIPs and FIUs. The AA ecosystem has also seen the participation of digital lending platforms and neo-banks such as Fi, Lendingkart and NeoGrowth Credit.

With the growth of digital lending and other fintech platforms in the country, the last-mile delivery of financial products that traditional channels have struggled with may witness an upsurge driven by the AA ecosystem.

Anu Tiwari and Anindita Bhowmik are partners at Cyril Amarchand Mangaldas. Associates Janak Panicker and Rohil Deshpande also contributed to this article

Cyril amarchand

Cyril Amarchand Mangaldas
Peninsula Chambers, Peninsula Corporate Park
Lower Parel
Mumbai 400 013, India

www.cyrilshroff.com

 

Contact details:
Tel: +91 22 2496 4455
Email: cam.mumbai@cyrilshroff.com

LinkedIn
Facebook
Twitter
Whatsapp
Telegram
Copy link
  • TAGS
  • Account Aggregators
  • Anindita Bhowmik
  • Anu Tiwari
  • Cyril Amarchand Mangaldas
Previous articleSettling disputes by mediation in Singapore and Thailand
Next articleRole of intermediaries in protecting Indian IP
ABLJ editor

RELATED ARTICLESMORE FROM AUTHOR

Hiral Motta Rejoins CAM
Market pulse

Hiral Motta returns to Cyril Amarchand as real estate partner

IHC Sammaan Capital Acquisition
Deal digest

Firms act on IHC’s USD1bn Sammaan Capital stake buy

Gokul Rajan
Deal digest

Firms assist on JSW Energy’s sale of shares in steel unit

Most Popular

The A-List Indonesia’s top lawyers 2026

The A-List: Indonesia’s top lawyers

Indonesia’s top 100 lawyers plus 41 Legal Icons

2 June 2026
Malaysia Law Firm Awards

Malaysia Law Firm Awards

Asia Business Law Journal names Malaysia’s top law firms

13 May 2026
Viernam Law Firm Awards 2026

Vietnam Law Firm Awards

Asia Business Law Journal reveals the country’s top law firms

8 May 2026
Indonesia’s top 100 lawyers plus 41 Legal Icons
Asia Business Law Journal names Malaysia’s top law firmsqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqqq
Asia Business Law Journal reveals the country’s top law firms

CORRESPONDENTS

Russian Court Jurisdiction Disputes

Russian courts expand their jurisdiction over international disputes

By Georgy Daneliya, Natalia Kozyrenko and Igor Sokolov, SL Legal
20 May 2026

Changing interpretation of cross-border service tax in Philippines

By Euney Marie Mata Perez, Mata-Perez, Tamayo & Francisco (MTF Counsel)
19 May 2026

Don’t judge land by its title: Lessons from spouses Manalese v Ferreras

By Nilo T Divina, Ciselie Marie T Gamo-Sisayan and Angel Isah M Romero, DivinaLaw
8 May 2026

IN-HOUSE AGENDA

Lee & Ko partner Yuseok Kim speaks during a seminar at the In-House Counsel Forum spring academy

Korean in-house counsel face compliance challenges: IHCF event

1 June 2026
KICA delegates share legal exchange in Tokyo with JILA

KICA delegates share legal exchange in Tokyo with JILA

21 May 2026

SCCA expands regional network with IHCF and LMCP partnerships

7 May 2026

News

DDSP Green Financing

Firms drive USD283m green financing for Malaysia data centre

4 June 2026

Firms aid Korean insurer in closing USD1.65bn US acquisition

4 June 2026
Thailand Employment Law

Tilleke & Gibbins brings in employment partner in Thailand

4 June 2026

FEATURES

The A-List Indonesia’s top lawyers 2026

The A-List: Indonesia’s top lawyers

Indonesia’s top 100 lawyers plus 41 Legal Icons

2 June 2026
Foreign Shipping In Korea

Staying afloat: Foreign shipping in Korea

By Choon Won Lee and Dahee Kim, Jipyong

South Korea’s maritime hub status grows with advanced ports, shipbuilding strength, trade volumes and dispute resolution.

28 May 2026
South Korea Global Standards Local Execution

Q&A: Korea’s global standards align with local execution

IHCF vice president SongYi Son discusses the merits and possible obstacles for doing business in South Korea

18 May 2026
Indonesia’s top 100 lawyers plus 41 Legal Icons
South Korea’s maritime hub status grows with advanced ports, shipbuilding strength, trade volumes and dispute resolution.
IHCF vice president SongYi Son discusses the merits and possible obstacles for doing business in South Korea

PRACTICE GUIDES

Wealth in transition

Wealth in transition

An unprecedented transfer of private wealth is colliding with tighter regulation and rising complexity

2 June 2026
Japan Taiwan Green Transition Strategies

Chasing zero

A closer look at how Japan and Taiwan are charting paths toward a low-carbon future

15 May 2026
An unprecedented transfer of private wealth is colliding with tighter regulation and rising complexity
A closer look at how Japan and Taiwan are charting paths toward a low-carbon future

JOBS

LAW.ASIA

Asia’s leader in legal intelligence

Law.asia is an award-winning portal providing news, analysis and expert advice on business law in Asia to in-house counsel, lawyers in private practice and other business and legal leaders. It features the proprietary editorial content and archives of our premium legal magazines – Asia Business Law Journal, China Business Law Journal and India Business Law Journal – along with videos, law firm listings, awards and much more. Produced by Law.asia Limited, an independent media company, Law.asia is multilingual, offering content in English, Chinese, Japanese and Korean. Find out more.
Follow Law.asia
Law firms Awards Events Legal jobs • Post a job
About us Archive Subscribe Contact us
Please send any press releases, deal announcements, details of new hires, newsletters and any other news items to: news@law.asia
  • Policy on advertising & sponsorship
  • Disclaimer
  • Terms & conditions of use
  • Privacy Policy
© Copyright 2026 Law.asia Limited. All rights reserved.

Follow us on LinkedIn

Follow now