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IAMAI Submission to DoT on Draft Telecommunications Amendment Rules Raises
Concerns of Regulatory Overreach
The Internet and Mobile Association of India (IAMAI) made a
submission to the Department of Telecommunications on the Draft Telecommunications
(Telecom Cyber Security) Amendment Rules, 2025 (Draft Amendments). The submission
expressed concern that the creation of "telecommunication identifier user entity"
(TIUEs), as proposed in the Draft Amendments, would impose high costs on digital
businesses and effectively bring them under a parallel telecom-like compliance
regime. Noting that neither the Indian Telecommunications Act, 2023 (Telecom Act)
nor the Telecommunications (Telecom Cyber Security) Rules, 2024 (Telecom CS Rules)
covered digital businesses, IAMAI pointed out that the inclusion of digital
businesses under the Draft Amendments would be in violation of the scope of the
Telecom Act and amount to regulatory overreach.
The Association also expressed concern around the proposed creation of a Mobile
Number Validation platform and imposition of a verification fee, underlining that
it could prove to be a significant expense and compliance burden for digital
businesses. The submission further pointed out that directing OTT platforms to
suspend the use of specific telecom identifiers for user identification or service
delivery without prior notice to the user could result in arbitrary and
unjustified user deactivation and service discontinuity. IAMAI requested the DoT
to keep the Draft Amendments in consonance with the Telecom Act and reconsider the
proposed introduction of TIUEs under the Telecom CS Rules.
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IAMAI Submission to MeitY on DPDP Act: Restrictions on Use of Publicly Available
Personal Data Likely to Hinder AI Ecosystem Growth
The IAMAI made a submission to the Ministry of Electronics and
Information Technology (MeitY) on the impact of the Digital Personal Data
Protection Act, 2023 (DPDP Act) on the Indian AI ecosystem. The submission
highlighted that ambiguities in the DPDP Act, 2023 surrounding the processing of
publicly available personal data might pose practical challenges for AI companies,
particularly those using large datasets for training their models. The IAMAI
underlined that restrictions on access to publicly available personal data would
impose undue compliance burdens on AI companies, hinder technological progress,
and could ultimately obstruct the realisation of AI's potential. Such limitations
would disproportionately affect startups and smaller companies developing AI
models. In its submission, IAMAI requested MeitY to suitably amend the DPDP Act to
remove barriers to using publicly available personal data for training or
fine-tuning of AI models.
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IAMAI Submission on Chandigarh Administration MVA Rules Urges Administration to
Align It with Central MVA Guidelines.
The IAMAI made a submission to the Chandigarh Administration on the
Chandigarh Administration Motor Vehicle Aggregator Rules, 2025 (Rules). The
submission urged the Chandigarh Administration to align the Rules with the Motor
Vehicle Aggregator Guidelines 2025 (MVA Guidelines) of the Union Government. The
IAMAI also requested the Chandigarh Administration to reconsider the prohibition
on the aggregation of non-transport (white plate) two-wheelers and the narrow
range for dynamic pricing prescribed in the Rules, in view of the MVA Guidelines
explicitly permitting the aggregation of non-transport two-wheelers and providing
a much broader pricing range that better accounts for supply-demand fluctuations.
The IAMAI also urged the Chandigarh Administration to withdraw the 2% state
surcharge under the Rules, in line with the revised national approach under the
MVAG.
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IAMAI's Digital Entertainment Committee Urges NPCI to Reconsider UPI Autopay
Retry Limits
The IAMAI's Digital Entertainment Committee (DEC) made a
representation to the National Payments Corporation of India (NPCI) regarding
Operational Circular 215A, which restricts the use of ten UPI APIs, including the
UPI Autopay transaction execution API. The DEC pointed out that limiting UPI
Autopay execution to one initial attempt and only three retries during non-peak
hours as a mitigation measure to prevent outages could severely impact the
effectiveness of payment flows and UPI Autopay adoption. The submission underlined
that such restrictive retry framework failed to accommodate genuine transactional
delays or system-level failures arising from intermittent connectivity, server
downtime, or delays at the bank or intermediary level, potentially leading to a
higher rate of payment failures. The DEC has proposed a principle-based approach
and suggested that, in the interim, the retry limit be increased from three to
seven attempts.
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IAMAI's PCI Provides RBI with Industry Feedback on Draft Circular to Simplify
Reconciliation Process for Small Value Exports
The Payments Council of India (PCI) made a submission to the
Reserve Bank of India (RBI) containing detailed industry feedback on the draft
circular by the RBI aiming to simplify the reconciliation process for small value
exports. The submission underlined the lack of standardisation between banks, lack
of operation clarity around documentation and other aspects, and the recognition
of platform enabled exports in guidelines allowing for variance in reconciliation,
among other issues.
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PCI's Cards Networks Committee Representation to RBI on Enhanced Security and
User Experience in Device Tokenisation.
The PCI's Cards Network Committee submitted industry inputs to
Reserve Bank of India (RBI) on enhancing security and user experience in device
tokenization. The industry made recommendations in alignment with RBI's Payments
Vision 2025, which include safer alternatives to SMS OTP such as push
provisioning, 3-5-minute OTP validity, SIM/device checks, and issuer-led risk
controls.
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PCI's UPI Committee Representation to NPCI on UPI Feature Flexibility and
Implementation
The PCI's United Payments Instrument (UPI) Committee made a
submission to the National Payments Corporation of India (NPCI) on TPAPs
flexibility in implementing UPI features. The industry proposed differentiation
mandatory features such as core UPI features, security and grievance-related
features and additional features which can be optional based on impact,
feasibility, and pilot outcomes.
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PCI-FCC Knowledge Session on Financial Crime and Compliance
Two of IAMAI's councils, the Payments Council of India (PCI) and
the Fintech Convergence FCC, in collaboration with Swift, organised a knowledge
session on 'Financial Crime and Compliance at Scale: Building Smarter, Connected
Systems' on 7th July 2025. The session was conducted by Ms. Charlotte Pardou,
Global Team Lead - Fincrimes and Fraud Solutions, Swift, and Mr. Tapas
Bhattacharya, Digital Currency and Interoperability, Swift. The speakers shared
insights on how large-scale, trusted networks such as Swift were tackling
financial crime and compliance challenges with a look at real-world use cases,
evolving regulatory demands, and how AI and new technologies were shaping the
response. The session was attended by over 160 industry professionals.
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FCC Knowledge Session on RBI's Draft Master Direction on Digital Banking
Channels Authorisation 2025
IAMAI's Fintech Convergence Council (FCC) and PW & CO LLP organised
a knowledge session on 25th July 2025, on the Draft Master Direction on Digital
Banking Channels Authorisation 2025, issued on July 21, 2025, by the Reserve Bank
of India (RBI). The session was conducted by Ms. Nidhi Biyani Jain, Associate
Partner, PW & CO LLP. Ms. Jain explained the implications of the draft direction
for regulated entities in the digital lending ecosystem and helped participants
understand the regulatory frameworks comprehensively. More than 80 attendees.
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FCC Knowledge Session on Navigating RBI's IT Master Directions
(2017-2023)
The FCC hosted a knowledge session in collaboration with PW & CO
LLP on 25th July 2025, titled 'Navigating Reserve Bank of India's Internet
Technology Master Directions (2017-2023) - A Compliance Centric Webinar for
Non-Banking Financial Companies and Fintechs'. The session was conducted by Mr.
Amol Bhat, Partner, PW & CO LLP and Mr. Amber Shah, Executive Director, PW & CO
LLP. The speakers discussed the compliance obligations, as outlined by the Master
Direction, across key areas and the challenges faced by non-banking financial
companies and fintechs. The session aimed at equipping participants with
actionable insights for aligning tech governance with regulatory expectations. 130
members took part in the session.
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Knowledge Session on 'Surviving a Breach: Incident Detection, Response &
Reporting for Lean Fintechs'
The FCC hosted a session focused on cybersecurity readiness for
resource-constrained fintechs on 18th July 2025, which was conducted by Dr.
Narayanan Krishnan, a renowned cybersecurity expert. Topics of discussion included
incident response planning, attack preparedness, and compliance regulatory
expectations. The session helped participants build practical frameworks to
address cyberattacks effectively while meeting mandatory regulatory obligations.
Emphasis was placed on proactive preparedness and cost-effective threat mitigation
in lean operating environments. Nearly 100 industry professionals attended the
session.
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Knowledge Session on SEBI's Master Circular for Stockbrokers
The FCC organized a knowledge session on 8th July 2025, on the
Master Circular for Stock Brokers, issued by the Securities and Exchange Board of
India (SEBI). It was conducted by Ms. R. Leelavathi Naidu, Senior Partner at IC
RegFin Legal (formerly IC Universal Legal), and attended by executives from 30
stock broking firms. The speaker provided clarity on compliance areas including
risk management, onboarding, grievance redressal, and algorithmic trading
disclosures. The session also addressed recent market infrastructure developments
and supervisory expectations of the regulator for brokers.
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Knowledge Session on Credit Insights: Key Trends & Forecast
The FCC, in collaboration with Experian, hosted a Knowledge Session
titled 'Credit Insights: Key Trends & Forecast' on 24th July 2025. The session was
conducted by Mr. Majid Asadullah, Head of Products, Experian India. The session
discussed emerging credit trends influencing borrower behaviour and insights on
lending decisions, and other issues. Eight industry professionals attended the
session.
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Virtual Panel Discussion on Agentic AI in Financial Services
The FCC organized a virtual panel discussion on 'Agentic AI in
Financial Services: Rewiring the Lending Ecosystem' on 2nd July 2025. The session
was moderated by Mr. Paritosh Desai, Chief Product Office, IDfy, with the Mr.
Hitul Mistry, CEO, Digiqt and Mr. Rumit Shah, Director, JISA Softech as the
speakers. The speakers discussed the implication of the use of agentic AI for the
lending ecosystem, real-world use cases, challenges, and regulatory
considerations. Over 170 industry professionals attended the panel discussion.
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GFF 2025: Don't Miss the Vast Expo and The Stunning AI Zone
The sixth edition of world's largest annual fintech conference, the
Global Fintech Fest (GFF), is less than two months away, scheduled for October 7 -
9, 2025, at Jio World Centre (JWC), Mumbai. While insights from luminaries of the
financial ecosystem, to be shared at 400+ sessions, including keynotes, panels,
fireside chats and roundtables, will be at the heart of the conference, GFF 2025
is designed to be much more than just speaking sessions. Abuzz with over 100,000
footfall of delegates from 40 countries, a huge expo will be one of the key
attractions of the conference. At the Pavilion and Jasmine Halls of the JWC, 300+
exhibitors, spread across 500+ booths and experience zones, will showcase the
latest products and services in fintech.
Leading players of the fintech ecosystem such as the NPCI, the SEBI, GooglePay,
PhonePe, Perfios, HDFC Bank, SBI, PNB, Amazon Pay, Razorpay, Paytm, VISA, Neokred,
Lyra, M2P Fintech, Route Mobile, OneCard, HSBC, Citi, Jocata, BharatPe, NABARD,
and PayU will set up stalls giving visitors a tour of fintech's future. The star
attraction will be the AI Zone, spotlighting the latest advancements in artificial
intelligence transforming financial services, from fraud detection to smart
underwriting.
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