Will AAs revolutionise India’s financial services? | Asia Business Law Journal

  • 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•Shanghai 2025
Events
Jobs
About us
Contact us
Follow Law.asia

Asia Business Law Journal
Asia Business Law Journal

    • 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
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
2391

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

  • 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

Vanya Singh joins Cyril Amarchand Mangaldas
Market pulse

Former SEBI expert to boost CAM’s dispute resolution practice

Meesho IPO legal advisers
Deal digest

Firms steer India e-commerce company Meesho’s proposed IPO

Runwal Developers IPO
Deal digest

CAM, Trilegal, Hogan Lovells steer Runwal’s INR20bn IPO bid

Most Popular

Korea Law Firm Awards

3 February 2026
Korean-Top Lawyers-2025

Korea’s Top Lawyers

Asia Business Law Journal unveils the A-List of Korea's top lawyers

31 October 2025
Indonesia Law Firm Awards 2025 V2

Indonesia Law Firm Awards 2025

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

18 September 2025
Asia Business Law Journal unveils the A-List of Korea's top lawyers
Asia Business Law Journal names the country’s top law firms

CORRESPONDENTS

Crypto Asset Remedies In BVI

Overview of remedies in BVI crypto asset disputes

By Edmond Fung, Loeb Smith Attorneys
12 November 2025

Inclusive workplaces: The Workplace Fairness Act

By Matthew Teo and Irvin Ho, Helmsman
12 November 2025
Philippines FIT-All 2025

Renewable power in the Philippines: FIT for purpose

By Jose M Layug Jr, DivinaLaw
11 November 2025

IN-HOUSE AGENDA

SCCA ESG Leadership Sustainability Connect Singapore

SCCA empowers in-house counsel in ESG leadership series

24 October 2025

APCCA names new secretary-general at Bali conference

24 October 2025
SCCA Great Gatsby Black-Tie Celebration

SCCA to turn 22 with Great Gatsby black-tie celebration

The SCCA will host a gala honouring leadership and pro bono excellence in the in-house legal field

21 October 2025

News

Jones Day Australia Finance Hire

Jones Day powers up APAC finance with Australia partner hire

12 November 2025
Greenberg Traurig Singapore Expansion

Greenberg grows Singapore bench in cross-border boost

12 November 2025
Baker Botts boosts global digital reach with Singapore partner-Joshua Cole

Baker Botts boosts global digital reach with Singapore partner

11 November 2025

FEATURES

REGIONAL COMPARISONS

Employment law challenges in Asia

Trends and challenges in employment law

Evolving worker classifications and stricter rules on dismissal highlight the challenges businesses face in navigating labour laws in these jurisdictions

16 September 2025

TMT in transition

Advances in technology are reshaping media and telecoms, with regulators in the Philippines

12 September 2025
Evolving worker classifications and stricter rules on dismissal highlight the challenges businesses face in navigating labour laws in these jurisdictions
Advances in technology are reshaping media and telecoms, with regulators in the Philippines

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.
Imagined by DOOD Website Design

Follow us on LinkedIn

Follow now