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 46 of 777 | M-PESA | One Great Bridge. Can Kenya Build Another?

 Published 20^th September 2026

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru

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

 

The Intro

Imagine Nairobi waking up one morning, reaching for M-PESA — and finding the bridge temporarily closed.

The Trigger  

On 17 September 2026, the FinTech Association of Kenya, through its Precursor publication, carried a striking thought experiment:

What if M-PESA took a week off?

Read the LinkedIn article @ https://www.linkedin.com/pulse/m-pesa-took-week-off-kenya-would-discover-gwuqf/

 

Not for an hour.

Not for a few minutes.

For a week.

Imagine Nairobi.

The office worker in Westlands reaching for the phone before the first meeting.

A matatu conductor waiting for the next passenger.

A boda rider in Kisumu completing a morning delivery.

A shopkeeper in Githurai serving the first customer of the day.

A family in Mombasa waiting for money to arrive.

The people are still there.

The goods are still there.

The money may still be there.

But the familiar digital bridge is not.

The article is not suggesting that M-PESA is failing. It is asking us to imagine what its absence would reveal about how deeply one payment rail has become woven into everyday economic life.

And that leaves Kenya with a simple question:

If one great bridge became unavailable,
would another bridge already be ready?

Citizen Observation

Perhaps it is time for Kenya to explore the possibility of another interoperable instant-payment bridge — not to replace M-PESA, but to add another route.

Brazil's Pix offers one international experience worth studying.

Not to copy.

Not to transplant.

Simply to explore.

---

Prospective Audience

Who would notice the difference if M-PESA were unavailable for a week?

Amina, opening her small shop in Githurai before sunrise.

Brian, a boda rider in Nairobi, waiting for his first customer.

Grace, running a family business in Mombasa.

David, travelling across Kisumu and depending on digital payments along the way.

A parent in Eldoret, waiting for money to reach home.

Different people.
Different places.
Different needs.

But one familiar question:

If the usual bridge is unavailable,
what is the other way across?

This is not about asking people to abandon M-PESA.

It is about asking whether resilience also means having another interoperable digital payment route ready when one major rail is unavailable.

 

Act I — The Week Without M-PESA

Imagine Monday morning in Nairobi.

At 8:03, someone in Westlands reaches for the phone.

M-PESA is down.

Not for an hour.

For seven days.

At a kiosk in Githurai, a customer wants unga, milk, cooking oil and bread.

KSh640.

“Till?”

“System iko down.”

The customer has money.
The shopkeeper has goods.

Only the familiar bridge is missing.

By afternoon, cash begins returning.

In Mombasa, a small business waits for a payment.

In Kisumu, a boda rider waits for a customer.

In Eldoret, a family waits for money from Nairobi.

Different places.

Different needs.

One missing bridge.

 

Act II — What If There Were Another Bridge?

The question is not whether M-PESA should disappear.

It is not.

M-PESA has become part of everyday economic life.

The question is simpler:

If one great digital bridge is unavailable,
should another bridge already be ready?

Brazil offers one experience worth studying.

Pix.

A nationwide instant-payment system built around participating financial institutions and interoperable payments.

Kenya need not copy Brazil.

It need not replace M-PESA.

But perhaps it can ask:

What could a second digital payment bridge look like for Kenya?

 

Act III — One More Way Across

Perhaps the next step is not to choose between payment systems.

Perhaps it is to create another route.

Study Pix.

Study Kenya.

Study what works.

Study what does not.

Then let the relevant institutions decide what, if anything, comes next.

Because resilience may not mean expecting the first bridge to fail.

It may simply mean:

When one bridge is closed,
another way across is already possible.

The Whiteboard

ONE GREAT BRIDGE.
CAN KENYA BUILD ANOTHER?

---

Why It Matters

A second bridge does not make the first bridge less important.

It simply creates another route.

For a customer, that could mean another way to pay.

For a merchant, another way to receive.

For a business, another way to keep moving.

For an economy, another layer of resilience.

The question is therefore not about replacing what Kenya has built.

It is about asking whether one successful payment rail should be the only digital bridge a country needs to depend upon.

Perhaps the answer already exists somewhere else.

Perhaps it needs to be designed differently for Kenya.

Perhaps it does not need to be built at all.

The observation is simply this:

A bridge becomes even more valuable when another bridge is available.

And perhaps Kenya is ready to explore what that second bridge could look like.

Closing Thought

A week without M-PESA is only a hypothetical.

But sometimes, a hypothetical helps us see what everyday life has stopped noticing.

The kiosk.
The matatu.
The boda.
The shop.
The family waiting for money.

All connected by a familiar digital bridge.

M-PESA has shown what one successful payment rail can become.

Perhaps the next chapter is not about replacing that bridge.

Perhaps it is about building another way across.

One great bridge.
Can Kenya build another?

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Disclaimer

This is a Citizen Observation, not a representation of the FinTech Association of Kenya, M-PESA, Safaricom, the Central Bank of Kenya, the Central Bank of Brazil, Pix, or any other institution.

The reference to Pix is only an international example for exploration. This observation does not propose copying Pix or prescribe any particular technology, architecture or implementation for Kenya.

The hypothetical M-PESA outage is used solely as a thought experiment to consider digital-payment resilience and the possibility of another interoperable payment route.

The views expressed are personal and intended to encourage constructive citizen dialogue.

The dialogue has begun, and hopefully it will move ahead.

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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 45 of 777 | UPI MDR | SEBI HEARS THE BROKERS | WHO WILL HEAR THE COMMON CITIZEN?

 Published 17 ^th September 2026

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru

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

 

1. The INTRO

A policy framework can affect different stakeholders in different ways.

When a stakeholder identifies a concern, raises it with the appropriate authority and receives a response, that becomes part of the policy conversation.

Stockbrokers have raised concerns. SEBI has said it will examine those concerns.

But this raises a broader question:

If the concerns of brokers can reach the regulator, can the concerns of the common citizen also reach the policy table?

This Citizen Observation is not about questioning whether brokers should be heard.

They should.

It is about asking whether the common citizen should also have a visible avenue to place a measurable policy suggestion before the decision-makers.

And this time, the suggestion is not merely a question.

It comes with a number.

2. THE TRIGGER

The immediate trigger for CO45 is the reported response of SEBI Chairman Tuhin Kanta Pandey to concerns raised by stockbrokers regarding the new UPI MDR framework.

Pandey said that SEBI would examine the issues raised by brokers and look at how they could be eased.

The significance for this Citizen Observation is not whether the broker concerns are ultimately accepted.

The significance is the policy-feedback mechanism:

Concern raised → Regulator responds → Issue gets examined.

That is an important part of how policy can evolve.

But it also provides an opportunity to ask a citizen-facing question:

What happens when the common citizen has a concern?

The UPI MDR framework is not merely a technical payment-system change. The structure of thresholds and charges can influence how different participants experience the digital-payment ecosystem.

So, alongside stakeholder concerns, can there also be room for a simple, measurable citizen suggestion?

CO45 attempts to place one on the table.

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3. PROSPECTIVE AUDIENCE

This observation is deliberately addressed to three audiences:

PMO — Decision Maker

The primary audience for placing the citizen proposal at the policy level.

SEBI — Interested Party

SEBI is directly relevant to this conversation because its Chairman has publicly responded to concerns raised by stockbrokers regarding UPI MDR.

Common Citizen — Most Affected Party

The citizen is not merely an observer of the policy conversation.

The citizen is one of the participants whose everyday digital-payment behaviour is shaped by the framework.

Prospective Audience: PMO | SEBI | The Common Citizen

And the central question remains:

SEBI hears the brokers.
Who will hear the common citizen?

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4. ABOUT THE ISSUE

The new UPI MDR framework introduces differentiated treatment for certain Person-to-Merchant (P2M) transactions.

Under the framework, specified P2M UPI transactions up to ₹2,000 remain outside MDR, while transactions above ₹2,000 attract MDR according to the applicable category. The framework is scheduled to take effect from 15 October 2026.

The ₹2,000 threshold therefore becomes an important reference point.

But a threshold created at one point in time does not necessarily remain equally relevant as transaction values change.

This is where CO44 raised the first citizen question:

IF THE BASKET GROWS, CAN THE FREE SLAB GROW TOO?

CO44 proposed:

₹2,000 → ₹2,100 → ₹2,200 → …

CO45 takes that thought one step further.

Rather than beginning the annual progression from ₹2,000, could the threshold first be reset to ₹2,500 when the new framework comes into effect?

And thereafter:

₹2,500 → ₹2,600 → ₹2,700 → ₹2,800 → …

with an annual increase of ₹100 every October.

The proposal is deliberately simple.

It does not attempt to redesign the entire UPI MDR framework.

It asks whether the starting point itself can be reconsidered, followed by a predictable annual adjustment.

CO44 asked whether the slab can grow.
CO45 asks whether the slab should first be reset — and then allowed to grow.

This is not presented as the only possible answer.

It is one measurable option placed before the decision-makers for consideration.

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5. ONE MEASURABLE SUGGESTION

Reset the Slab. Then Let It Grow.

New Delhi. September 2026.

A concern has been placed on the table.

Stockbrokers have raised concerns about UPI MDR.

At the policy table, SEBI Chairman Tuhin Kanta Pandey has said that SEBI will examine those concerns and see how they can be eased.

Now, imagine another voice entering that same policy conversation.

Not a broker.

Not an industry association.

A common citizen.

And instead of arriving with a complaint, the citizen arrives with one number, one date and one simple mechanism.

₹2,500.

The citizen suggestion:

Reset the UPI MDR free slab from ₹2,000 to ₹2,500 from October 2026.

Then let it move predictably:

₹2,500 → ₹2,600 → ₹2,700 → ₹2,800 → ₹2,900 → …

with ₹100 added every October.

October	Proposed Slab
2026	₹2,500
2027	₹2,600
2028	₹2,700
2029	₹2,800
2030	₹2,900
Thereafter	+₹100 every October

Why this suggestion?

Because the citizen is not asking for an open-ended exemption or a complicated new mechanism.

The proposal has:

A number — ₹2,500
A date — October 2026
An increment — ₹100
A frequency — every October

The annual increment can be reviewed by the appropriate authorities if circumstances warrant a different approach.

So the proposal is not presented as the only answer.

It is one concrete option placed before the decision-makers — to accept, modify or reject.

And here is the citizen's moment at the table:

The brokers have placed their concern.
SEBI has said it will hear them.

Here is the common citizen's proposal.

₹2,500 now.
₹100 more every October.

One number. One date. One predictable path.

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6. READY-TO-USE SOLUTION

RESET → INDEX → REVIEW

RESET

₹2,000 → ₹2,500 from October 2026

INDEX

₹2,500 → ₹2,600 → ₹2,700 → ₹2,800 → ₹2,900 → …

+ ₹100 every October

REVIEW

The mechanism can be reviewed periodically by the appropriate authorities and modified if circumstances warrant.

One simple mechanism. One measurable citizen option.

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7. WHY IT HELPS

A predictable annual adjustment could provide:

Predictability — a clearly defined annual movement.

Transparency — the adjustment is visible rather than requiring a fresh policy discussion each time.

Simplicity — one number, one annual increment and one review mechanism.

Citizen participation — a general concern becomes a specific policy option.

It does not assume that ₹2,500 or ₹100 is permanently correct.

It simply places a measurable option before the appropriate decision-makers:

Consider it. Modify it. Or reject it.

But let the citizen proposal be heard.

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8. CLOSING THOUGHT

SEBI HEARS THE BROKERS.
WHO WILL HEAR THE COMMON CITIZEN?

A stakeholder raised a concern.

The concern reached the regulator.

The regulator said it would examine the issue.

Now the common citizen places a different kind of concern on the table — not merely a complaint, but a measurable suggestion.

₹2,500 from October 2026.
₹100 more every October thereafter.

If stakeholders can put their concerns on the table, can the common citizen's concern have a seat at the same table?

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9. THE WHITEBOARD

THE BROKERS BROUGHT A CONCERN.

THE CITIZEN BRINGS A NUMBER.

₹2,500 → ₹2,600 → ₹2,700 → ₹2,800 → …

+ ₹100 EVERY OCTOBER

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10. DISCLAIMER

Citizen Observation 777 is intended to start conversations, not conclude them.

This proposal is offered purely from a citizen's perspective and may be accepted, modified, reviewed or rejected by the appropriate authorities based on wider policy considerations.

A beginning has to be made, and this is the beginning.

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11. APRIL 11 — DIGITAL TRANSACTIONS DAY

April 11 — Digital Transactions Day

UPI began its beta journey on April 11, 2016.

Digital payments are shaped not only by transactions, but also by the rules and choices that govern them.

CO45 is one small citizen suggestion in that continuing journey:

As there seem to be opportunities for stakeholders to put forward their suggestions, this is one small step towards that.

As of now, I am not sure what shape this will take, but the prayer for the limit to be increased to ₹2,500/- will continue.

Listen to the stakeholders. Hear the citizen. Keep improving the system.

The guide for Citizen Observation 45 is Chapter 2, Verse 47 of the Bhagavad Gita, where Lord Krishna tells Arjuna that you have a right to do your work, but you do not control the results.

The only Joy is —

The Joy of Digital Transactions

Advocating Digital Transactions Day (April 11)

This version retains your important distinction: the proposal is being pursued with effort, but without claiming control over the outcome.

 

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