Webinar | 17 December 2025
As the Account Aggregator (AA) ecosystem continues to scale across India’s financial sector, the way financial data is accessed and used has never been more important. While consent-based data sharing has unlocked faster, more efficient digital lending journeys, it has also made one principle central to the ecosystem’s long-term trust and sustainability, Fair Use.
On 17 December 2025, Sahamati hosted a focused webinar titled “Fair Use Explained: What are the guardrails for Lending Journeys on Account Aggregator?” to help ecosystem participants better understand how Fair Use is designed, implemented, and enforced within the AA framework.
The session was hosted by Geethashree Srikanta, from the Governance team, and brought together lenders and ecosystem participants to discuss how fair use guardrails are designed for responsible data sharing across lending journeys.
Why Fair Use Matters in Lending
As data sharing has become easier, data requests have expanded in scope and frequency, making Fair Use essential as a discipline of transparency, restraint, and responsibility for the lenders.
Fair Use ensures that:
- Purpose Limitation – Data is collected only for a clearly defined legitimate purpose aligned with industry practices.
- Collection Limitation – Only the minimum data necessary for the defined purpose is requested.
- Storage Limitation – Data is stored only for the duration required to fulfil the defined purpose.
These guardrails protect customers while also giving lenders a predictable, trusted environment in which to build scalable digital products.
What the Webinar Covered
The session explored how Fair Use principles apply to lending use cases under the Account Aggregator (AA) framework. Drawing from real questions raised by lenders and ecosystem participants, the discussion focused on:
- How Fair Use templates can be utilised across different lending journeys
- What types of financial data may be requested for credit assessment
- How long data may be retained and whether it can be reused
- How purpose limitation, collection limitation, and storage limitation work together in practice
The discussion helped clarify how lending institutions can remain within community-defined upper limits while still designing efficient, data-driven credit products.
Key Fair Use Guardrails Discussed
- CC026: One Purpose, One Consent
- Each consent must map to exactly one declared purpose
- Multiple purposes cannot be combined or layered in a single consent
- Underwriting, monitoring, and collection must remain distinct journeys
- Monitoring Guardrails (CT003 / CT035)
- Monitoring consents apply only to active loan accounts
- They cannot be used to expand or revisit underwriting
- Data use must remain strictly within the declared monitoring purpose
- Collection Template – Use Only in Default
- Applicable only once a loan has entered default
- Cannot be used for underwriting or monitoring
- The purpose is limited solely to recovery-related assessment
- Why the PFM Template Cannot Be Used for Lending
- PFM and lending serve fundamentally different purposes
- They involve different services and data lifecycles
- Using PFM for lending would violate the “one purpose, one consent” principle
Missed the Webinar?
Watch the full session to gain a deeper understanding of how ecosystem participants can better comprehend how Fair Use is designed, implemented, and enforced within the AA framework.
Presentation is here
For any questions or to explore how your organisation can participate in the AA ecosystem, write to us at https://sahamati.org.in/contact/. There is a dedicated field for fair use questions.