Code of Conduct for Sahamati Members
The AA Master Directions issued by RBI and Technical Specifications published by ReBIT provide an overarching framework to guide dos and don’ts of Sahamati members and other regulated entities participating in the account aggregator (“AA”) ecosystem.
These codes of conduct address various ‘operational’ issues that arise while operating in the AA ecosystem, and provide clarity on issues of interpreting the above-mentioned high-level directions/specifications. These codes of conduct are crafted to operate as lower-level procedural decisions that are understood and implemented uniformly by Sahamati members and other regulated entities participating in the AA ecosystem.
Such “procedural decisions” are the product of community deliberations in one or more of the committee(s), user council(s) and/or working group(s) that Sahamati facilitates.
Once such procedural decisions are published in the form of code(s) of conduct, they are required to be adhered to by all Sahamati members and other regulated entities participating in the AA ecosystem, based on the treatment mentioned in such code(s) of conduct i.e. mandatory vs. recommendatory.
Such code(s) of conduct usually also make their way into the various checklists published by Sahamati to guide implementations and conduct of Sahamati members in the AA ecosystem.
Sahamati members and other participants in the AA ecosystem are expected to not proceed with divergent implementations. While market pressures motivate faster consensus on such matters, they should not be reasons for divergent behaviours, as that may be detrimental to end customers as well as the AA ecosystem at large.
Modifications to such code(s) of conduct, based on newer market feedback or regulatory guidance, are, of course, to be handled from time to time through further deliberations in the relevant committee(s), user council(s) and/or working group(s), if required.
This document aims to consolidate all code(s) of conduct (and their lifecycle stage) discussed thus far, across Sahamati’s committees, user councils and working groups.
Enforcement of Sahamati’s Codes of Conduct
Enforcement of adherence follows a three-step process:
- Clarity and explanation – through checklists circulated by Sahamati.
- Review of checklists and explanation of deviations – during onboarding assistance provided by Sahamati.
- Transparency of information pertaining to adherence – through public dashboards available on Sahamati’s 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 Sahamati members and other regulated entities participating in the AA ecosystem on convergent thinking on various subjects. Such clarity is expected to foster adherence and healthy discussions amongst Sahamati members and other ecosystem participants. This document is intended to serve such an audience.
This document includes the ‘Treatment’ of each Code of Conduct as Mandatory, Recommended or Clarificatory, which should be understood as below:
- Mandatory – This means that the code of conduct must be followed by all Sahamati Members. The general expectation from the community is that all participants adhere to these codes of conduct.
- Recommendatory – This means that the code of conduct has been agreed by the broader community as a best practice for Sahamati Members and other participants.
- Clarificatory – This means the code of conduct aims to clarify either an ambiguity arising from the relevant ReBIT specifications, or matters of general importance which should be consistently adopted by Sahamati Members and other participants.
How to read this document:
- If you are an FIU, please refer to Chapters I and II.
- If you are an AA, please refer to Chapters I and III.
- If you are an FIP, please refer to Chapters I and IV.
Online access to these Codes of Conduct
These codes of conduct are available on Sahamati’s website at