Sometimes citizen participation is not about being right. It is about contributing thoughtfully.
Published 01 June 2026
By Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru
Advocating Digital Transactions Day (April 11)
The consultation window for the Reserve Bank of India's draft
directions relating to technology-based restriction of functionalities of
financed mobile devices has now concluded, and my submission has been formally
shared with RBI.
As a full-time banker and part-time citizen observer, I
approached this consultation not from the perspective of a lender, borrower,
technology provider or industry participant, but as someone interested in the
long-term evolution of India's digital financial ecosystem.
The objective of my representation was not to oppose the
proposed framework, nor to advocate for any particular commercial outcome.
Instead, the submission focused on a simple question:
How can technology-enabled recovery mechanisms be
implemented in a manner that balances innovation, borrower protection,
operational clarity and public confidence?
The observations shared with RBI centred around regulatory
clarity, repayment accessibility, transparency, restoration processes and
long-term governance considerations.
With the submission process now complete, I hope RBI has
received a diverse range of perspectives from financial institutions,
technology providers, consumer advocates, borrowers and interested citizens.
Consultations such as these are among the strengths of India's
regulatory ecosystem. They create opportunities for ideas to be examined,
challenged, refined and, where appropriate, incorporated into future policy.
The sections below provide a summary of the key themes
highlighted in my representation.
Executive Summary
The Reserve Bank of India's revised draft directions on
technology-based restriction of functionalities of financed mobile devices
represent an important milestone in the evolution of India's digital lending
ecosystem.
After reviewing the draft framework, I submitted a
citizen-observer representation to RBI. My feedback broadly supports the
objective of balancing borrower protection, recovery effectiveness, responsible
innovation and long-term market development.
Rather than focusing on whether device-restriction mechanisms
should exist, my observations focused on how such mechanisms may be implemented
in a transparent, customer-centric and operationally sustainable manner.
The key themes highlighted in my submission were:
1. Regulatory Clarity
The draft directions refer to a borrower's mobile device,
including mobile phones and tablets.
I suggested that additional clarity around the scope of
"mobile devices" may support consistent implementation, reduce
ambiguity and facilitate smoother grievance resolution in the future.
2. Recognising a
Distinct Lending Category
Technology-enabled device-restriction loans differ from
conventional retail loans.
I proposed that RBI may consider creating a separate
regulatory category for such products, supported by enhanced disclosures,
informed consent standards and customer communication requirements.
Such an approach could also improve supervisory visibility as
this segment evolves.
3. Preserving
Repayment Accessibility
One of the observations submitted was that a borrower should
not lose the ability to digitally cure a digital default.
India's UPI and BBPS infrastructure provides a unique
opportunity to ensure that borrowers retain practical access to repayment
channels throughout the restriction lifecycle.
4. Transparency and
Restoration
The draft directions contain important borrower-protection
measures, including restoration timelines and compensation provisions.
My submission suggested that restriction and restoration
should be viewed as two parts of the same customer journey, supported by clear
communication, auditability and customer visibility of key events.
5. Responsible
Innovation and Governance
Technology-assisted recovery mechanisms should complement
responsible lending practices, not replace them.
As adoption grows, governance frameworks, complaint
monitoring, restoration performance and customer outcomes may become equally
important indicators of success.
Closing Note
The draft framework has the potential to create a new category
of technology-enabled lending products within India.
Its long-term success may depend not only on the effectiveness
of the restriction mechanism itself, but also on the transparency, repayment
accessibility, restoration efficiency and governance standards that surround
it.
My representation has now been submitted, and I look forward
to seeing the collective feedback received by RBI during the consultation
process. As always, these observations were shared in the spirit of
constructive engagement and responsible innovation within India's digital
lending ecosystem.
The Joy of Digital Transactions - Nayakanti
Prashant
Author’s Blogs
https://prashantrandomthoughts.blogspot.com
https://prashantnepayments.blogspot.com
https://innovationinbanking.blogspot.com







