The AA Master Directions issued by RBI and Technical Specifications published by ReBIT provide an overarching framework to guide dos and don’ts of participants in the AA network.
There are, however several questions that arise during implementation, which involve interpreting the above-mentioned high-level directions/specifications and crafting lower-level procedural decisions that are understood and implemented uniformly by all AA participants.
Such “procedural decisions” (henceforth referred to as “guidelines”) are the product of community deliberations in one or more of the steering committees and/or working groups that Sahamati organizes.
Each such guideline follows a lifecycle of passing through two stages within the community forum that is discussing it:
● “Is Under deliberation.”
● “Is Finalised.”
Guidelines agreed to
All guidelines that reach a stage of agreement (“Is Finalised”) are expected to be adhered to by all community members. Modifications to such guidelines, based on newer market feedback or regulatory guidance, are, of course, to be handled from time to time.
Such guidelines usually would also make their way into checklists that guide implementations. Optionally, some of these guidelines may be incorporated in future versions of the AA Ecosystem Participation Terms.
However, the incorporation or otherwise, into checklists and the Participation Terms has no bearing on the expectation of adherence. Once a guideline reaches a stage of agreement, it is expected to be adhered to, in good faith, by all community members.
Guidelines under deliberation
Guidelines that are still under deliberation are also expected to be implemented in a spirit of consensus. In other words, the fact that a guideline is under deliberation implies that there is a need felt for a harmonious understanding and implementation of that aspect.
Market participants are expected to not proceed with divergent implementations without submitting their views to the community forum. Market pressures should certainly motivate faster consensus on such matters but not be reasons for divergent behavior, as that may be detrimental to both customers and ecosystem participants.
This document aims to provide a list and details of all guidelines (and their lifecycle stage) discussed thus far across Sahamati Steering committees and working groups.
Enforcement of adherence to guidelines
Enforcement of adherence follows a three-step process:
- Clarity and explanation – through checklists and ecosystem participation terms
- Review of checklists and explanation of deviations – during onboarding assistance provided by Sahamati to every participant.
- Transparency of information pertaining to adherence – through public dashboards available on the Sahamati website
Punitive measures to ensure enforcement of such guidelines are outside the scope of this document.
The overarching spirit of this document is to provide clarity to all participants on what convergent thinking on any subject is. Such clarity is expected to either foster healthy debate or adherence amongst most participants. This document is intended to serve such an audience.
Summary of the Guidelines
As of this version, there are 120 guidelines grouped across 25 topics as listed below.
|Serial No.||Topic||Guidelines Finalised||Guidelines under deliberation|
|1||Customer registration and de-registration||2||3|
|2||User Identification and Authentication||2||2|
|4||Account Linking and Delinking||2||2|
|5||Consent Request Management||5||8|
|6||Data Request Management||1||3|
|7||Consent Lifecycle Management||1||2|
|8||Recurring Consents Management||0||4|
|9||Customer as a Data Recipient||1||3|
|10||Unregulated Entities and their Roles||1||2|
|11||FIU Roles and Responsibilities||3||4|
|12||FIP Roles and Responsibilities||2||4|
|15||Central Registry and Token Issuance Service||4||0|
|18||AA Client Integration||6||5|
|21||Grievance and Dispute Resolution||3||1|
|23||API Implementation Best Practices||2||1|
|24||Storage of Data||2||2|