The Reserve Bank of India should obtain self-certification from relevant e-commerce entities that comply with applicable regulations, Consumer Unity and Trust Society (CUTS) said in its submission to the central bank. CUTS also said that RBI should not ask the e-commerce companies to create a separate entity for conducting its payment aggregators' (PA) and payment gateways (PG) business. The RBI had released a discussion paper on guidelines for payment aggregators and payment gateways in September. The key recommendations have been summarised below: Recommendation 1: Reconsider the regulatory approach for e-commerce marketplaces. Instead of asking market players to change their business architecture, RBI could ask them for self-certification of compliance with applicable regulations instead. RBI should not ask the e-commerce firms to create a separate entity for conducting payment aggregators/gateways business. It should instead ask companies to create a virtual information barrier between different departments to address concerns of conflict of interest. Recommendation 2: Do not restrict PAs and PGs from dealing with merchants who do not have a physical presence in the country. Merchants are appropriately verified at the time of account opening and onboarding. Once on board, the regulator should treat all merchants equally, irrespective of their physical presence. Recommendation 3: Adopt a risk-appropriate capital requirement, as the capital of minimum net worth of Rs 100 crore for PAs/PGs is a market barrier. This risk-based graded approach should be linked with value of gross outstanding transactions, or a similar indicator. RBI should not treat all kinds of PAs/PGs similarly, as the…
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