In response to the evolving landscape of user-consented data sharing within the Account Aggregator (AA) ecosystem, the need for a more scalable, transparent, and community-driven approach towards data collection and usage has become increasingly apparent. In view of the DPDP Act, 2023, and the increasing usage of AA across sectors, AA market participants collectively sought harmonization of industry standards and practices for participation in the AA framework for the various use cases it enables. Based on such feedback, Sahamati introduced the AA Fair Use Library as a community asset to harmonize consent attributes, setting upper-bound reference parameters for various use cases across sectors.
Establishing the Fair Use Library represents a transformative step towards promoting fair usage of AA by fostering greater trust, transparency, and efficiency within the AA ecosystem. At its core, the Fair Use Library serves as a comprehensive repository of standardized fair use templates, meticulously crafted by the Use Case Councils and Fair Use Committee to align with the diverse needs and use cases of Financial Information Users (FIUs) while ensuring they meet the business requirements, and enhance customer privacy and are aligned with the principles of the DPDP Act, acting as guardrails against misuse of AA framework.
What is a Fair Use Template?
A Fair Use Template refers to the outer bounds for mandatory attributes (as defined by the ReBIT specs) of consent artefact that can be employed for a specific use case. While few attributes, such as purpose code, consent type, fetch type, etc. are described in absolute terms, attributes that carry a value and unit are described as upper bounds.
Who created the Fair Use Library?
The formation of the Fair Use Library involved a collaborative effort by active Financial Information Users (FIUs) within the Account Aggregator (AA) Ecosystem, through the individual User Councils, which was further reviewed and approved by the Fair Use Committee and Governing Council of Sahamati. These templates, designed as “Best Practice Consents Templates,” were meticulously crafted through collaborative efforts and rigorous deliberations led by leading industry practitioners. Key considerations during the design process included safeguarding end-customer interests, ensuring alignment with the principles of the Digital Personal Data Protection (DPDP) Act, adhering to RBI master guidelines for AA, and addressing the specific requirements of various use cases.
Usage of Fair Use Library
The templates were developed to serve as benchmarks for data-collection practices within the AA ecosystem, providing a standardized framework that promotes transparency, fairness, and alignment with regulatory and statutory principles. Expectations are set for Financial Information Users (FIUs) and Account Aggregators (AAs) to revise their Fair Use Templates within the parameters of those in the Fair Use Template Library, ensuring consistency and adherence to established parameters.
For instance, FIUs offering Spend and Investment Analytics use cases will, as per the Fair Use template library, be expected to declare the frequency of their data pulls at 45 or less than 45 data pulls, with a consent validity of one year or less.
Fair Use Template Library
The table below summarises the templates discussed or finalized by the Use Case Councils.
| Fair Use Template ID | Use Case Category | Finalised by | Status | Purpose Text (to customers) | |
|---|---|---|---|---|---|
| CT001 | Loan Underwriting | Lending Use Case Council | Active | To process borrower’s (loan / credit card / credit line) application | |
| CT003 | Account Monitoring | Lending Use Case Council | Active | To monitor the borrower’s account to verify the repayment capability, subject to activation of (loan / credit card / credit line) | |
| CT004 | Wealth Management Services | PFM Use Case Council | Active | To provide (Wealth Management) / (Advisory) Services | |
| CT006 | Income verification | Insurance Use Case Council | Active | To verify the income as or on behalf of the insurer selected by the customer while underwriting a Life insurance policy | |
| CT008 | Personal Finance | PFM Use Case Council | Active | To generate insights based on your overall finances and provide incidental recommendations, if any | |
| CT035 | Account Monitoring | Lending Use Case Council | Active | To monitor a borrower’s accounts for (loan / credit card / credit line) collection, in case of overdue payments | |
| CT040 | Bank Account Verification | Cross Sectoral Use Case Council | Active | To verify (financial account type) account details for (activity/product) | |
| CT042 | Account Monitoring | Lending Use Case Council | Active | To monitor the counterparty risks of Recovery Agents/ Sourcing Partners. | |
| Last published | 10th August 2024 |
Please note that the parameters of the individual Fair Use templates in the Fair Use Template Library represent upper bounds for the respective use cases, as decided in the relevant User Councils. The parameters in the Fair Use templates should be treated by participant(s) as outer limit(s) and not be construed as legal advice in any manner. Participants are encouraged to review their use case(s) and ensure compliance with applicable laws, including the RBI Master Directions on NBFC-AA and the DPDP Act.
Sahamati will publish additional Fair Use templates as the AA ecosystem evolves based on discussions in the relevant Use Case Councils and the Fair Use Committee. Existing Fair Use templates may also be revised based on statutory and regulatory guidance, including the DPDP Act and the Rules issued thereunder.
