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Fair Use Explained: Understanding Process-Based B2B Templates and Guardrails

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May 14, 2026 2 min. Read

As adoption of the Account Aggregator (AA) framework expands across sectors and use cases, consented data sharing is no longer limited to customer-facing financial products like lending or personal finance management. Increasingly, as Regulated Entities automate business processes, individuals can securely share financial information as part of employment disclosures, vendor onboarding, compliance reporting, counterparty assessments, or government program participation. To harmonize how such data-sharing flows are designed across the ecosystem, Sahamati’s Fair Use Library was developed as a community-built reference framework that sets upper bounds for harmonizing different use cases.

On April 28, 2026, as part of our continuing series on Fair Use Explained, Sahamati hosted a webinar led by Geethashree Srikanta from the Governance team, exploring how participatory governance within the AA ecosystem is shaping responsible data-sharing practices. The session focused specifically on process-based (B2B) templates and guardrails, helping teams working on enterprise risk, compliance, operational monitoring, and onboarding workflows understand how financial data access should be structured on the AA rails to ensure compliance.

How to Choose the Right Template and Avoid Misuse

The session offered participants a complete introduction to the fair use framework and showed them how Sahamati enables its adoption across the AA ecosystem. In this context, it discussed the following five key B2B templates, tailored for process-driven use cases that are not always customer-facing, emphasizing their purpose and boundaries:

  • CT040 – Cross Validation:  Generic templates for any Financial Information Users (FIUs) requiring cross verification of an account as per their license regulations.
  • CT043 – Employee Compliance Reporting: Designed for all entities covered under SEBI PIT regulations. 
  •  CT045 – One-time Employee / Vendor verification: Generic template for any FIU to review the complete financial condition of individuals. 
  • CT042 – Employee / Vendor Monitoring: Monitor the counterparty risks of Recovery Agents / Sourcing Partners / Employees.
  • CT047 – Government Scheme Beneficiary monitoring: Designed to measure the efficacy and impact of government schemes.

The session outlined the clear guardrails and codes of conduct Sahamati has defined during the adoption of these templates to reinforce trust and ensure that data usage remains aligned with user expectations.

Missed the Webinar

Watch the full session to gain a deeper understanding of how ecosystem participants can implement Fair Use within the AA framework.

Watch the full webinar here.

Download the presentation here.

For any questions or to explore how your organization can participate in the AA ecosystem, write to us at https://sahamati.org.in/contact/. There is a dedicated field for fair use questions.

 

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