Citizen Observation 68 of 777 | Account Aggregators | Different Apps, Same Journey — Why Not Common Core T&C?

Published 20^th October 2026

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru

https://in.linkedin.com/in/prashantnayakanti

 | Account Aggregators | 

 

The Intro

Different Account Aggregator apps.
Same customer journey. Why not a common core of Terms & Conditions?

The Trigger

A recent Sahamati development on standardised pricing for the Account Aggregator ecosystem made me pause.

If the ecosystem can move towards common standards for how participants are compensated, could we also explore a common core of customer-facing Terms & Conditions?

Not identical in every detail. Just a common core, with AA-specific details simply filled in the blanks.

The Prospective Audience

• Existing AA User — someone already using an Account Aggregator.
• First-Time AA User — someone encountering the registration T&C for the first time.
• Future AA User — someone who may enter consent-based financial data sharing as adoption grows.
• Financial Consumer — the person ultimately expected to understand and exercise control over their data.
• Account Aggregators — the entities presenting the customer-facing registration journey.
• Financial Information Providers (FIPs) — institutions holding the customer's financial information.
• Financial Information Users (FIUs) — institutions requesting and using information with customer consent.
• Sahamati — coordinating the ecosystem and playing a formal ecosystem governance role.
• Regulators & Policy Makers — responsible for the framework within which this consent-led ecosystem operates.
• Fintech & Open Finance Community — building the applications and journeys around AA.
• Digital Public Infrastructure Community — looking at how common standards can improve citizen experience.
• Everyday Financial Consumer — because standardisation ultimately matters when the person using the system finds it easier to understand.

And at the centre of it all:
The customer who ultimately clicks “I Agree”.

Absolutely. Keeping the architecture simple, constructive and citizen-centric, and making the “common core + fill in the blanks” idea the thread running through the three Acts:

The Act I — Different Apps, Same Journey

When a customer enters the Account Aggregator ecosystem, the first step is usually familiar:

Register → Discover → Select → Consent → Share → Manage

The app may be different.
The organisation may be different.
The screen may look different.

But the fundamental customer journey remains broadly the same.

And somewhere at the beginning of that journey, the customer is asked to read and accept the Terms & Conditions.

That made me wonder:

Does the customer really need to encounter a different core set of terms simply because the AA app is different?

 

The Act II — What If the Core Was Common?

I am not suggesting that every Account Aggregator should have identical Terms & Conditions.

There will always be details specific to the individual AA:

Company identity
Contact details
Service-specific provisions
Applicable charges
Technical / platform matters

Why not treat these as the fill-in-the-blanks?

The core could remain common:

Customer rights → Consent → Data sharing → Privacy → Revocation → Grievance → Customer responsibilities

So the proposition becomes simple:

One common customer-facing core.
AA-specific details filled in separately.

 

The Act III — From Legal Consistency to Customer Simplicity

For the ecosystem, standardisation can make processes easier to understand and implement.

For the customer, the benefit could be even simpler.

If I move from one AA app to another, I should not have to relearn the fundamental principles of the relationship.

The brand can change.
The interface can change.
The company details can change.

But the core customer promise could remain familiar.

That is where I see the value of a common-core approach.

Not to remove choice.

To make choice easier to understand.

 

The Citizen Observation

Perhaps the Account Aggregator ecosystem has an opportunity to make its customer journey even more citizen-friendly.

Different apps.
Same journey.
Common core.

And then simply:

Fill in the blanks.

Could a common core of customer-facing Terms & Conditions make the AA experience simpler, more consistent and easier for an ordinary financial consumer to understand?

One observation at a time.

Nothing More – Nothing Less

 

The Closing Thought

Standardisation is often discussed from the perspective of institutions.

Perhaps we should also look at it from the perspective of the person who clicks:

“I Agree.”

If the journey is common,
could the core promise be common too?

 

April 11 — Proposed Digital Transactions Day

The Account Aggregator journey is another reminder that digital transactions are increasingly about more than simply moving money.

Identity. Consent. Data. Choice. Control.

All can form part of a digital financial journey.

That is why I continue to propose:

April 11 — Digital Transactions Day.

A day to recognise not just digital payments, but the wider digital journeys shaping how citizens interact with financial services.

Move the Barrier — Proposed Digital Transactions Day

Digital Payments are a sub – set of Digital Transactions.

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Disclaimer

This is an independent citizen observation, based on publicly available information and my personal perspective on customer experience in the Account Aggregator ecosystem.

The suggestion of a common-core T&C with AA-specific fill-in-the-blanks is a citizen proposal, not a statement of regulatory policy or an assertion that existing AA Terms & Conditions are deficient.

It is not intended to comment on or criticise any particular Account Aggregator, Sahamati, FIP, FIU or regulator.

 

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

 

Citizen Observation 67 of 777 | UPI 54 Pages Circular – P9 | Nine Posts. One Customer Journey.

 Published 17^th October 2026

Nayakanti Prashant | 3rd Gen Banker & Citizen Lobbyist – Bengaluru

Advocating Digital Transactions Day (April 11)

The Introduction

A 54-page circular. Eight observations. And one question that connects them all.

When we look at UPI through a citizen’s eyes, the journey is not limited to initiating or completing a payment.

It also includes what we see, what we understand, what we know, what we can control, and what we can trace.

What we can trace, becomes important sometimes after the transaction is over.

Across this mini-series, we have explored individual parts of that journey.

Now, it is time to step back and look at the customer experience as a whole.

Trigger

The UPI Consolidated Circular, Version 1.0, dated 18 September 2026, brings together provisions covering multiple parts of the UPI ecosystem.

Across this mini-series, we have approached selected parts of that 54-page document through a simple lens: what might they mean to the person making or receiving a payment?

Now, as we reach the final post, the focus shifts from individual observations to the journey connecting them.

The question is no longer about one feature or one transaction. It is about the experience of the customer across the journey.

Prospective Audience

This observation is for every citizen who uses UPI in everyday life—and for those across the banking and payments ecosystem who help shape that experience.

For the customer who makes a quick payment, the family member who asks what a transaction meant, the merchant who accepts digital payments, and the professionals who design and deliver these services, the journey is experienced in different ways.

The common thread is the customer.

Can the journey be seen, understood, known, controlled and traced—not merely completed?

Act I — The Everyday Journey

A UPI payment can take only a few moments.

We open an application, choose a recipient or scan a QR code, authenticate and wait for the outcome.

But the customer’s experience does not necessarily begin and end with that moment.

What did I see? What did I understand? What did I authorise? And if I need to revisit the transaction later, what will help me make sense of it?

These are ordinary questions from an ordinary customer’s point of view.

Act II — Eight Observations, Different Windows

Across this mini-series, we looked at selected parts of the UPI Consolidated Circular through different customer-facing windows.

Communications. UPI Number. Merchant visibility. AutoPay. UPI Lite. Biometric authentication. Credit Line on UPI.

Each observation began with a different subject, but the underlying curiosity remained the same: how does the customer experience the feature, the information and the choices around a digital transaction?

The observations were not intended to explain every provision in the circular or cover every possible customer concern. They were a way of looking beyond the document and towards the person experiencing the payment journey.

Act III — The Journey Connects

A payment is one moment. The customer journey is the larger picture.

A message may help me understand what happened. A visible identifier may help me recognise whom I am paying. A choice may help me decide whether to proceed. Information may help me revisit a transaction and explain it later.

And sometimes, as CO65 asked, the question may arise in an ordinary conversation at home:

“I paid using credit through UPI. Can I explain what I used?”

The spouse or partner is not the subject of a separate technical issue here. That everyday conversation simply reminds us that digital transactions are part of life beyond the screen.

The customer journey connects the payment, the understanding and the conversation that may follow.

Citizen Observation

Eight observations. One customer journey.

The value of looking at a digital payment does not lie only in whether the transaction was completed. It also lies in what the customer could see, understand, know, control and trace along the way.

This mini-series offers eight selected observations—not a verdict on the UPI ecosystem, and not a claim that every customer faces the same experience.

It is an invitation to keep the customer’s perspective in view.

Closing Thought

The circular may be written for the ecosystem.

The journey is experienced by the customer.

And that journey deserves to be seen as a whole.

A Small Link to April 11 — Proposed Digital Transactions Day

April 11 is proposed as Digital Transactions Day.

Beyond celebrating the growth of digital payments, it could also offer an opportunity to reflect on the citizen’s experience: not only how many transactions take place, but how clearly people can understand and navigate their digital transaction journeys.

Please note, Digital Payments are also a sub-set of Digital Transactions.

And that is one more reason I continue to advocate:

April 11 — Digital Transactions Day.

April 11, 2016 is UPI Beta Launch.

 

Disclaimer

This is an independent citizen observation based on selected customer-facing themes in the UPI Consolidated Circular, Version 1.0, dated 18 September 2026. It is not a comprehensive summary or technical interpretation of the circular, a regulatory opinion, or an assessment of any particular bank, UPI application or product.

The observations are intended to encourage constructive reflection on customer experience. April 11 as Digital Transactions Day is a proposal, not an officially declared observance.

A start has to be made somewhere.

---

Three series. One purpose. Countless conversations.

CO 777 — Citizen observations
DTD 777 — Digital transactions day
DC 777 — Donation coins

 

The Joy of Digital Transactions

Nayakanti Prashant

https://in.linkedin.com/in/prashantnayakanti

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

 

Citizen Observation 66 of 777 | NHAI & IHMCL | FASTag @ Delhi Airport | Thank You for the Quick Response

 Published 16^th October 2026

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru

https://in.linkedin.com/in/prashantnayakanti

 

The Intro

A FASTag experience at Delhi Airport caught my attention—not only because of the concern raised, but because of what happened next.
A citizen question reached the system, NHAI & IHMCL responded quickly, and the course was corrected.

The  Trigger

The trigger for this Citizen Observation was user feedback about FASTag at Delhi Airport's Terminal 3.

Reports indicated that vehicles were being diverted when they did not meet certain FASTag-related entry conditions, raising concerns about the limited free waiting period. The issue was raised publicly, including on social media, and reached the authorities.

What caught my attention was not only the concern.

It was the response.

NHAI took cognisance.
IHMCL stepped in.
Directions were issued to discontinue FASTag-based entry restrictions.
And the restrictions were subsequently lifted.

That made me pause.

We often talk about convenience, automation and seamless digital journeys.

But perhaps another dimension deserves equal attention:

How quickly does the system listen when a citizen says, “Something doesn't feel right”?

For me, CO66 is therefore not about criticising FASTag.

It is about appreciating responsive regulation when a citizen-facing digital experience needs correction.

 

The  Prospective Audience

The Immediate User

The person driving into Delhi Airport T3 to pick up or drop off a passenger—experiencing the payment system not as policy, but as a real-world journey.

The FASTag User

Motorists who expect FASTag to make payments automatic, contactless and predictable.

The Occasional Airport Visitor

Someone unfamiliar with the latest parking or FASTag arrangements. For such users, clarity is part of convenience.

The Citizen Who Raises a Question

The person who notices something unusual, speaks up, posts about it or brings it to the appropriate institution.

Sometimes the first signal that a digital process needs examination comes from the person actually using it.

The Regulator

NHAI, IHMCL and similar institutions that sit between technology, operators and citizens.

CO66 is also a small appreciation of an important regulatory function:

Listening → Examining → Responding → Correcting

The Payment Ecosystem

Banks, FASTag issuers, parking operators and technology partners implementing digital payments on the ground.

A payment technology may be technically seamless, but the citizen experience around it matters too.

The Airport & Mobility Ecosystem

Airports, parking operators, transport authorities and mobility platforms integrating digital payments into physical movement.

When payment technology becomes part of a journey, the boundaries between payment, access and convenience need to remain clear.

The Digital Public Infrastructure Community

Those building India's next generation of digital infrastructure.

The broader design principle is simple:

Digital infrastructure should not only work. It should remain understandable, predictable and responsive to the citizen.

And Finally — Every Citizen

Because this observation is bigger than FASTag.

It is about something we all want from the systems we use:

When we raise a genuine concern, will someone listen?

And when the answer is yes, perhaps we should say that too.

Thank you, NHAI & IHMCL, for the quick response.

 

Act I — When a Payment Journey Meets a Physical Journey

A FASTag is designed to make a payment journey simple.

At Delhi Airport's Terminal 3, that digital journey meets a very physical one.

A vehicle arrives.
The FASTag is read.
The vehicle moves forward.
A passenger is picked up.
And, where applicable, the parking fee can be collected digitally.

That sounds simple.

But recent user feedback around T3 raised another question:

What happens when the payment mechanism itself starts influencing where a vehicle can enter or how the journey proceeds?

For a citizen, the distinction may be small on a screen—but very real on the road.

That is where this observation began.

 

Act II — Payment Should Facilitate the Journey

The issue was not whether FASTag should be used at an airport.

Using FASTag for parking payments can make the experience contactless, convenient and cashless.

The question was about its purpose.

If FASTag is being used to collect a parking fee, the relationship seems simple:

Vehicle enters → Parking happens → Applicable fee → Digital payment

But if FASTag status or balance becomes a condition for entering a particular area, its role appears to move beyond payment.

That is where the regulatory response caught my attention.

NHAI took cognisance and clarified that FASTag should not be used to enforce entry restrictions. IHMCL directed the concerned bank to discontinue such restrictions.

For me, the principle is simple:

Payment should facilitate the journey—not silently redefine the journey.

Act III — Thank You, NHAI & IHMCL

This is the part of the story I want to acknowledge.

A citizen-facing issue emerged.
Users spoke about their experience.
The concern reached the authorities.

NHAI took cognisance.
IHMCL responded.
Directions were issued.
The FASTag-based entry restrictions at T3 were subsequently lifted.

That deserves recognition.

We often describe digital transformation through:

RFID.
FASTag.
Automation.
Cashless payments.
Real-time processing.

But another dimension matters just as much:

Responsiveness.

When something doesn't work as intended, can the citizen's experience reach the institution?

And when it does, can the institution respond quickly?

For this episode, my answer is simply:

Thank you, NHAI & IHMCL, for the quick response.

 

Citizen Observation 66 of 777

Perhaps the most encouraging part of this episode is not that a digital system encountered a question.

Digital systems will always evolve.

The more important observation is what happened after the question was raised.

A citizen experience became visible.
The regulator examined the issue.
The intended role of FASTag was clarified.
Corrective action followed.

That makes me think:

A good digital ecosystem is not one where nothing ever goes wrong. It is one where genuine concerns can be heard—and corrected.

FASTag can make a journey smoother.

Regulation can help keep the technology within its intended purpose.

And citizens can contribute by observing, questioning and sharing their experiences.

One observation at a time.

Closing Thought

There is something reassuring about seeing a digital system corrected without losing sight of the citizen using it.

The technology can be sophisticated.
The infrastructure can be complex.

But the principle can remain simple:

**Make the payment easy.

Keep the journey clear.
Listen when the citizen speaks.**

And sometimes, a Citizen Observation does not end with a demand.

Sometimes it ends with two words:

Thank you.

Thank you, NHAI & IHMCL, for the quick response.

 

April 11 — Digital Transactions Day

This FASTag episode gives me another reason to think about April 11 — Digital Transactions Day.

The FASTag journey at the airport is completely digital:

FASTag → RFID reading → Vehicle identification → Parking process → Digital system

But there is an interesting distinction:

A digital journey does not necessarily mean a financial transaction has happened.

A vehicle may enter.
FASTag may be read.
The system may recognise the vehicle.
The journey may continue.

And if the vehicle remains within the permitted free period, there may be no parking fee to pay at all.

So:

The journey is digital.
The identification is digital.
The process is digital.
But the financial transaction may be NIL.

For me, that expands the meaning of digital transactions.

Perhaps Digital Transactions Day should not be understood only as celebrating money moving digitally.

It can also recognise the increasingly digital journeys through which citizens interact, authenticate, access, move and transact.

Please note, Digital Payments are also a sub-set of Digital Transactions.

And that is one more reason I continue to advocate:

April 11 — Digital Transactions Day.

April 11, 2016 is UPI Beta Launch.

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Additional Reading

• Indian Express — NHAI tells banks not to allow FASTag to restrict entry at Delhi Airport
• Indian Express — FASTag at Delhi Airport: Can payment systems be used to restrict entry?
• Times of India — T3 parking operator used FASTag to restrict entry; payment facility suspended
• Times of India — NHAI warning prompts IGI T3 parking operator to lift FASTag curbs
• IHMCL — Official website and FASTag resources

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Disclaimer

This Citizen Observation is an independent citizen perspective based on publicly reported information and user feedback. It is not a complaint against NHAI, IHMCL, Delhi Airport, any bank, parking operator or FASTag participant.

The appreciation expressed here is specifically for the reported regulatory response to the entry-restriction issue.

This post does not represent any official position of the organisations mentioned.

FASTag arrangements, airport parking rules and regulatory directions may change. Readers should refer to official sources for the latest applicable position.

 

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

 

Citizen Observation 65 of 777 | UPI 54 Pages Circular – P8 | I Paid Using Credit — Can I Explain It to My Spouse?

 Published 15^th October 2026

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru

https://in.linkedin.com/in/prashantnayakanti

 

The Intro

I paid using credit through UPI. Later, in an ordinary conversation, my spouse asks, “What exactly did you use?”

Can I explain it clearly—not just that I made a payment, but what kind of credit transaction it was?

The Trigger

The trigger is Section 26 — Credit Line on UPI (Credit on UPI), pages 32–33, of the UPI Consolidated Circular, Version 1.0 dated 18 September 2026.

The circular describes pre-sanctioned credit lines as a source of funds on UPI.

It distinguishes interest-free credit lines from interest-bearing credit lines and refers to their use across different UPI features.

Yes, Credit on UPI Lines can be interest free or interest bearing.

One provision particularly caught my attention. Section 26.11 refers to standardising account subtypes and reference numbers to harmonise the user experience and reduce friction at the point of payment.

I am not reading this as evidence that customers cannot currently identify their credit transactions. Instead, it prompts me to consider a simple, everyday question.

When I pay using credit through UPI, will I understand the nature of that transaction—not just when I make the payment, but when I look back at it later?

And if someone close to me asks what I used, can I explain it in my own words?

For me, that is the citizen observation worth exploring.

Prospective audience

This observation may resonate with:

• UPI customers who use, or are considering, a credit line for payments.
• Customers curious about their source of funds and the distinction between paying from a bank account and using credit.
• People who revisit their payment history, notifications or statements and want to understand the nature of a transaction.
• Households that discuss everyday finances, where one person may naturally ask another, “What exactly did you use?”

I am not approaching this as a credit-product reviewer or a technical expert. I am approaching it as a customer asking a simple question:

When I pay using credit, do I understand it well enough to explain it to someone close to me?

Act I — The conversation

The payment is done. Later, my spouse asks a simple question: “What exactly did you use?”

It is not a complaint or a challenge. Just the kind of question that can come up when two people share the details of everyday life.

I know I made a payment through UPI. But can I explain whether I used my bank account or a credit line—and, if I used credit, what kind of credit transaction it was?

That small moment makes me pause.

Act II — What the circular makes me notice

Section 26 of the UPI Consolidated Circular describes Credit Line on UPI and distinguishes interest-free credit lines from interest-bearing credit lines. It also refers to their use across different UPI features.

Section 26.11 particularly stands out: it refers to standardising account subtypes and reference numbers to harmonise the user experience and reduce friction at the point of payment.

I do not take this to mean that customers are necessarily confused today. Instead, it raises a question for me: as credit becomes another source of funds for UPI payments, will the customer be able to understand and explain the transaction afterwards?

The payment experience matters. So does the understanding that stays with us after the payment.

Act III — The everyday test

Imagine looking back at a UPI payment and being asked, “Was that from your bank account or through credit?”

If through Credit, than which Credit Line?

The customer-facing test is simple: can I recognise what I used, understand the nature of the transaction, and explain it in ordinary language?

This is not about expecting every customer to know the terminology in a circular. It is about whether the experience leaves the customer with enough clarity to answer a straightforward question at home.

For me, that is where convenience meets understanding.

Citizen Observation 65 of 777

A UPI payment may take only a moment. Understanding what I used to make that payment should not have to be a mystery.

When credit becomes a source of funds on UPI, the customer’s experience extends beyond completing the transaction. It includes recognising the nature of that transaction and being able to explain it in everyday language.

My observation is not that customers cannot do this today. It is that customer understanding deserves to remain part of the journey.

Sometimes, the simplest test is a question asked at home.

Closing thought

A payment is complete when the transaction goes through. The experience feels complete when the customer understands it, too.

April 11 — Digital Transactions Day

April 11 is proposed as Digital Transactions Day—a day to reflect not only on the growth of digital payments, but also on the experience of the people who use them.

As UPI journeys evolve, the conversation must remain bigger than transaction completion. Can citizens see, understand and explain the digital transactions they make?

That, too, belongs in the joy of digital transactions.

The larger Digital Transactions Day advocacy continues separately at Move the Barrier.

Move the Barrier

April 11 2016, is the UPI Beta Launch Day.

 

Disclaimer: This post is an independent citizen observation based on Section 26 of the UPI Consolidated Circular, Version 1.0 dated 18 September 2026. It reflects a personal customer-experience perspective and is not a technical interpretation, regulatory opinion, credit recommendation or assessment of any particular bank, UPI application or credit product. April 11 as Digital Transactions Day is a proposal.

 

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