Published 20th October 2026
Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru
https://in.linkedin.com/in/prashantnayakanti
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.
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
