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Framework for recognising Self-Regulatory Organisations for the Account Aggregator Ecosystem (SRO-AA)

Reserve Bank of India (RBI) has invited applications for recognition of Self-Regulatory Organisation for the Account Aggregator ecosystem (SRO-AA).

Who are Account Aggregators (AAs)?

Account Aggregators (AAs) undertake the business of account aggregation, i.e., retrieve / collect specified financial information from Financial Information Providers (FIPs) and aggregate, consolidate and present such information to the customers or Financial Information Users (FI-Us).

What is the need of Self-Regulatory Organisations for Account Aggregator ecosystem (SRO-AA)?

The FIPs and FI-Us fall under the purview of different Financial Sector Regulators (FSRs), i.e., Reserve Bank of India (RBI), Securities and Exchange Board of India (SEBI), Insurance Regulatory and Development Authority of India (IRDAI), Pension Fund Regulatory and Development Authority of India (PFRDA). Further, Department of Revenue is deemed to be the regulator for Goods and Services Tax Network for the purpose of onboarding the AA ecosystem.

The AA ecosystem is distinct in its complexity, involving exchange of data among a diverse array of Regulated Entities (REs) operating under varied regulatory environments. This complexity necessitates frequent coordination among these REs to address various operational issues such as dispute resolution, standardized agreements, common services, etc. Given its inherent diversity and to support its smoother adoption and stabilisation, it is desirable to have a dedicated Self-Regulatory Organisation for the Account Aggregator ecosystem (SRO-AA).

What shall be the characteristics of SRO-AA?

The SRO-AA is expected to operate under the oversight of RBI and should have the following characteristics –

  • True Representation of the AA ecosystem – The SRO-AA should endeavour to become a true representative of the AA ecosystem, encompassing regulated entities of FSRs acting as NBFC-AAs, FIPs and FI-Us. This representative structure should foster inclusivity and enable the SRO-AA to draw upon the collective expertise and experience of its members, resulting in development of rules that are pragmatic, adaptive and widely accepted within the ecosystem. 
  • Code of Conduct and Oversight – The SRO-AA should set ethical, professional and governance codes, in relation to the participation in the AA ecosystem and monitor the compliance of these codes by the members. It should have strong governance mechanisms, including focus on independent board, transparency and adherence to well-defined processes for overseeing activities of their members.
  • Development-oriented Activity – The SRO-AA should offer support, expert guidance and capacity building initiatives to enable its members to seamlessly adopt and implement the technical requirements of the AA ecosystem. The SRO-AA should educate public about the aspects related to account aggregation, open finance, etc.
  • Independence from Influence – It is expected that the SRO-AA functions above self-interest of any sort and addresses larger concerns of the ecosystem and financial system as a whole. To maintain credibility, the SRO-AA should operate independently, free from the influence of any single member or group of members. While acting as the industry representative, the SRO-AA is expected to ensure equitable and transparent treatment for all its members.
  • Grievance Redressal and Dispute Resolution – The SRO-AA should devise and implement standardised procedures for grievance redressal and handling disputes among members.

What shall be the objectives of SRO-AA?

The SRO-AA is expected to achieve the following objectives –

  • Adopt objective, well-defined and consultative processes to make rules relating to conduct of its members and be able to monitor the compliance of these rules.
  • Promote a culture of compliance of regulatory compliance and public good by the participants of the AA ecosystem.
  • Act as the collective voice of its members in providing suggestions to / engagements with RBI, other FSRs and other stakeholders.
  • Collect and share relevant information with RBI to aid in policymaking.
  • Undertake / encourage a culture of research and development within the AA ecosystem to encourage innovation while ensuring highest standards of compliance and self-governance.

What shall be the eligibility criteria for SRO-AA?

  • The applicant should be set up as a not-for-profit company registered under Section 8 of the Companies Act, 2013.
  • The applicant should have / demonstrate to achieve a minimum net worth of ₹2 crore within one year after recognition as an SRO-AA by RBI, or before commencement of operations as an SRO-AA, whichever is earlier. Thereafter, the SRO-AA shall maintain the minimum required net worth on an ongoing basis.
  • The shareholding of the SRO-AA should be sufficiently diversified and no entity shall hold 10% or more of its paid-up share capital, either singly or acting in concert.
  • The applicant must possess / demonstrate the ability to create necessary infrastructure to enable it to discharge responsibilities of the SRO-AA effectively and consistently. 
  • The applicant and key executives must have professional competence and have general reputation of fairness and integrity to the satisfaction of RBI. 

What shall be the criteria for membership of SRO-AA?

  • The participants of the AA ecosystem, viz., NBFC-AAs, FIPs and FI-Us, are eligible to become members of the SRO-AA. 
  • The membership for SRO-AA is voluntary. SRO-AA should ensure that its members should evenly include all the types / classes of FIPs and FI-Us. To ensure balanced representation, the SRO-AA shall have at least 25 unique entities each from FIPs and FI-Us as its members at all times, subject to review. Failure to maintain the same, would render the SRO-AA liable for revocation of the recognition granted.
  • The membership fee structure developed by the SRO-AA should be reasonable and non-discriminatory. While membership fees may vary or be differentiated, based on size, intent, capability, etc., it should be ensured that the membership character remains non-discriminatory.
  • The SRO-AA should derive necessary powers through the membership agreements to set rules, codes of conduct, etc. for its members and monitor compliance thereto.

What shall be the criteria for the Board of SRO-AA?

  • At least 1/3rd of members in the Board, including the Chairperson, should be independent and without any active association with the participants of the AA ecosystem.
  • Not more than 1/4th of the members in the Board shall be nominated by NBFC-AAs.
  • To ensure that all sectors / types of participants of the AA ecosystem are duly represented, the Board should have a good mix of Directors with varied expertise and experience from FIPs and FI-Us. At least one director should possess expertise in regulations of banks and financial services. 

What shall be the responsibilities of SRO-AA towards FSRs?

The SRO-AA shall discharge the following responsibilities towards the FSRs –

  • The SRO-AA should keep RBI regularly informed of the developments / trends / concerns in the ecosystem to complement the oversight. It shall also promptly inform RBI and other FSRs about any violation by its member of the provision of the Acts or the rules / guidelines / regulations / directions issued by RBI / other FSRs, that comes to its notice.
  • The SRO-AA should carry out any work assigned to it by RBI and examine the proposals or suggestions referred to it.
  • The SRO-AA shall provide data / information, sought by RBI / other FSRs periodically or as advised.
  • The SRO-AA should submit an Annual Report to RBI and other FSRs, within 3 months of completion of the accounting year. The SRO-AA shall submit the periodic / adhoc returns as may be sought by RBI / other FSRs.
  • The SRO-AA should engage in periodic interactions with RBI. It is expected that SRO-AA would look at the larger picture of the ecosystem in offering its views / inputs / suggestions.
  • The SRO-AA should discharge such other functions and also abide by such other directions as specified by RBI from time to time.
  • RBI may, if it deems necessary, inspect the books of the SRO-AA or arrange to have the books inspected by an audit firm. The expenses of such inspection shall be borne by the SRO-AA.

How shall the application of SRO-AA be processed?

  • An entity aspiring to function as an SRO shall make an application to RBI for recognition.
  • Where the applicant is deemed suitable, RBI would issue a “Letter of Recognition” as the SRO-AA.


References

Reserve Bank of India. (2025, March 12). 'Framework for recognising Self-Regulatory Organisations (SROs) for the Account Aggregator Ecosystem'. Retrieved from https://www.rbi.org.in/Scripts/PublicationReportDetails.aspx?UrlPage=&ID=1291

Reserve Bank of India. (2025, March 12). 'Invitation of applications for recognition of Self-Regulatory Organisation(s) for the Account Aggregator Ecosystem'. Retrieved from https://www.rbi.org.in/Scripts/BS_PressReleaseDisplay.aspx?prid=59956


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