The Deadline Is the Last Date. Does It Have to Be Our Submission Date?
The Regulator Creates Time to Participate. Perhaps
We Should Create Time to Participate Well.
Published: 27 July 2026
Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru
The Starting Point
Dear Reserve Bank of India Team,
At the outset, appreciation for a regulatory practice that
deserves recognition.
Before many regulatory proposals become final, RBI places
drafts in the public domain and invites comments from stakeholders and members
of the public.
On June 24, 2026, RBI invited comments on the draft Guidance
on Regulatory Principles for Model Risk Management, 2026.
The last date was July 24, 2026, with a digital
submission route through Connect 2 Regulate.
My experience produced an observation.
This time, however, it is not primarily for the institution.
It is for the participant on the other side of the
consultation.
Act I | The Invitation
June 24, 2026.
A draft appears on the RBI website.
Model Risk Management.
Governance.
Artificial Intelligence and Machine Learning.
Oversight. Controls. Risk.
Technical subjects.
But alongside them is something remarkably simple:
An invitation to comment.
The regulator has opened the door before the regulatory
journey is complete.
Stakeholders can study.
Experts can suggest.
Institutions can respond.
Citizens can participate.
And there is a date:
July 24, 2026.
A month can look like plenty of time.
Until it becomes...
the last day.
Act II | The Final Click
The draft is downloaded.
Read.
Re-read.
Paragraphs are marked.
Suggestions are drafted, rewritten and checked.
Eventually, the feedback is ready.
Only one step remains.
Submit.
In my case, that step came on July 24 itself.
I opened Connect 2 Regulate.
Instead of the expected submission page:
“You are not authorized to view this page. Please
contact concerned Support Team.”
Suddenly, a date that looked like available time...
became very little time.
Fortunately, RBI had also provided an email address for
comments and attachments.
The feedback was submitted through that route.
The submission went out.
And a lesson came back.
Act III | The Observation Turns
Around
It would be easy to make the portal error the Citizen
Observation.
But there is another side.
The consultation opened on June 24.
The deadline was July 24.
I chose to complete my submission on the last day.
So perhaps the first question should not be:
What could the institution have done differently?
Perhaps, this time:
What could I have done differently?
The answer is simple.
Submitted earlier.
Act IV | One Citizen Suggestion
For anyone participating in a public consultation, could we
adopt one simple personal discipline?
Treat T-1 as our target.
Where circumstances permit, aim to submit at least one
working day before the official deadline.
The official deadline remains unchanged.
Our personal target simply moves earlier.
That small margin can help when a portal behaves unexpectedly,
an attachment needs correction, a final review takes longer, or something
unforeseen happens.
The regulator gives us a consultation window.
Perhaps we should leave ourselves a little window
within that window.
The First Line on the Whiteboard
Citizen Observation 777 draws only the first line
on the whiteboard.
Sometimes that first line is for an institution.
Sometimes it is for the citizen looking back from
the other side of the whiteboard.
CO11 is one of those occasions.
The institution invited participation.
My learning is to participate a little earlier
next time.
Act V | Before the Circular Goes
Live
There is something valuable about being invited to comment before
a regulatory proposal reaches its final form.
The regulator drafts.
The consultation opens.
Stakeholders respond.
Inputs are considered.
Eventually, the regulatory journey moves forward.
No participant should assume that a suggestion will
necessarily be accepted.
That is not the point.
The opportunity to contribute before finalisation
is itself valuable.
And when an institution creates that opportunity...
perhaps our responsibility is not merely to participate.
It is to give our participation the time it
deserves.
Citizen Observation
CO11 leaves me with one simple lesson:
A deadline is the last date to submit.
It need not become the day we choose to submit.
For future public consultations, my starting point will be:
Official Deadline: T
Personal Target: T-1 Working Day
Not because the institution asks for it.
Because a little margin can protect the effort invested before
the final click.
The regulator creates time for us to participate.
Perhaps we should create time for ourselves to
participate well.
Disclaimer
Citizen Observation 777 is built on a simple
belief: every meaningful improvement begins with someone willing to draw the
first line on a blank whiteboard.
These observations are intended to start conversations, not
conclude them.
CO11 reflects a personal submission experience and the
learning drawn from it. The design and operation of regulatory consultation
channels rightly remain with the Reserve Bank of India and its relevant teams.
The April 11 – Digital Transactions Day Philosophy
Citizen Observation 777 believes that thoughtful digital
journeys matter across different forms of citizen participation.
A consultation is published digitally.
A draft is accessed digitally.
Feedback is prepared and submitted digitally.
The experience reminds us that good digital journeys work best
when institutions create opportunities and citizens participate
thoughtfully.
That philosophy also inspires the proposal to recognise April
11 as Digital Transactions Day — UPI Birthday.
Digital Payments is a sub-set of Digital Transactions.
The universe of Digital Transactions covers Digital Payments
too.
The Joy of Digital Transactions
Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru
Advocating Digital Transactions Day (April 11)
Author’s Blogs
https://prashantrandomthoughts.blogspot.com
https://prashantnepayments.blogspot.com
https://innovationinbanking.blogspot.com
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