The increasing usage of digital payments in India has highlighted the role of intermediaries, such as payment gateways and payment aggregators, that facilitate such transactions. Such intermediaries are currently subject to indirect supervision by RBI. Given the increasing role and importance of such entities in the payments value chain, on 17 September 2019, RBI issued a discussion paper on “Guidelines for Payment Gateways and Payment Aggregators” (“RBI Discussion Paper”) for stakeholder comments. Vidhi Centre for Legal Policy has submitted its comments on the proposed regulatory approaches and the guidelines discussed in the RBI Discussion Paper. We hope that our comments will be useful in designing a meaningful regulatory framework for such payment intermediaries.
Shehnaz is a Senior Resident Fellow with the Corporate Law and Financial Regulation vertical. Her areas of interest include the intersection of law and digital economy and business and human rights. At Vidhi, she has worked with various Ministries/Departments and a multilateral institution on various projects involving research and drafting support on areas diverse areas including financial resolution, digital economy (including payment systems law), business and human rights and competition law. Shehnaz graduated from RML National Law University in 2011. She has authored independent projects on tech-based interventions for regulating payment wallets, blueprint of a National Health Insurance Law and reforms for competition law. Prior to joining Vidhi, she headed a law firm (Zeta Law Chambers) co-founded by her, the Financial Regulatory Practice at Cyril Amarchand Mangaldas, Mumbai and the Dispute Resolution team at J. Sagar Associates. She has written for publications such as Oxford Business Law Blog, Financial Express, Firstpost and Business Standard.