Dvara Analysis Weblog | Response to Niti Aayog’s Dialogue Paper on “Digital Banks – A Proposal for Licensing and Regulatory Regime in India”



Deepti George
Madhu Srinivas

Niti Aayog launched a dialogue paper in November 2021 outlining a proposal for licensing and regulating Digital Banks (DBs) in India. The dialogue paper defines DBs as “Banks as outlined within the Banking Regulation Act, 1949 (B R Act). In different phrases, these entities will challenge deposits, make loans and provide the complete suite of companies that the B R Act empowers them to. Because the title suggests nonetheless, DBs will principally rely on the web and different proximate channels to supply their companies and never bodily branches.[1] (emphasis added within the authentic). Successfully, DBs might be considered a decreased type model of current banks that present all of the companies of incumbent banks however are constrained to function primarily by way of digital channels. The dialogue paper highlights some credit score market failures and gaps that, it argues, can greatest be solved solely by creating and regulating a brand new class of banks, the DBs. In our response, we query the assumptions put forth by the dialogue paper for the creation of DBs and the concomitant licensing and regulatory regime. We spotlight and elaborate the interior inconsistencies and contradictions within the arguments furthered by the dialogue paper for the creation of DBs within the method prescribed. We conclude that monetary inclusion doesn’t current a robust case for the DB assemble, however somewhat that DBs could possibly be licensed with the intention to speed up competitors within the digital monetary service and banking house.

Figuring out the Market Failure and Mis-identifying the Intervention

The dialogue paper highlights a ‘market failure’ within the debt marketplace for MSMEs whereby incumbent banks are unwilling to lend to MSMEs, who’re in any other case creditworthy, resulting from lack of documentation and thereby resulting in suboptimal outcomes for each banks and MSMEs[2]. Including to those frictions is the excessive operational value construction of banks which makes it unviable for them to underwrite small ticket MSME loans[3]. The paper then states that NBFCs, whereas with the ability to remedy the underwriting downside that banks have, are unable to boost funds as cheaply as banks, as a result of absence of a ‘financial institution license premium’, which, the paper claims, is a premium supplied by the credit score market to borrowing entities.   

As an answer to those issues, the paper suggests the creation of DBs, that are prone to have a a lot decrease value construction. Nonetheless, the dialogue paper additionally means that the onerous compliance necessities on MSMEs, for availing mortgage from banks, flows from the standing of banks as regulated entities and fiduciaries[4]. Thus, we conclude that DBs, which might even be regulated entities and fiduciaries akin to banks, will probably be topic to the identical compliance necessities as banks and thus the prevailing frictions that the paper factors to, would proceed to persist for the DB assemble too.

Economics of the DB Assemble

The dialogue paper does little to clarify the economics of the DB assemble and the way DBs would obtain profitability. It contrasts the low per-account working value of Webank in China with the cost-to earnings ratios of banks in India to counsel DBs in India can be worthwhile. Nonetheless, the Buyer Acquisition Price (CAC) is predicted to be comparatively excessive and is predicted to rise with higher competitors[5]. Provided that small ticket, low tenure MSME and retail loans would type a major marketplace for DBs, the CACs wouldn’t be a one-time value however prone to be a recurring value[6]. Even assuming a low working value construction, the traditionally excessive NPA ranges on this phase implies that DBs would nonetheless face excessive credit score prices[7]. The excessive credit score prices, mirrored by the provisioning for anticipated losses on loans, and relative focus of their portfolio within the city areas, would adversely have an effect on their profitability. The dialogue paper doesn’t present any arguments or illustrations of how anticipated losses might be introduced down by way of the DB assemble and therefore, by not doing so, it doesn’t present a reputable argument for a way the DB assemble will remedy the important thing value challenges of serving low-income and under-served segments. Additionally, the opposite argument for the profitability of the DB assemble hinges on entry to low-cost retail demand deposits. The fact of the artificially low-cost nature of retail deposits displays the woefully low competitors in rate of interest choices on retail demand deposits amongst banks in India. In contrast to most banks worldwide, Indian banks take pleasure in just about assured income from the ‘depositor penalty’ that they collectively and unfairly impose on their depositors. Within the U.S., as an example, the ‘depositor penalty’ has been near 0.10% on a mean up to now six years, as in comparison with 4% in India over the ten years since deposit charges have been deregulated[8]

For sure, with nearly all of India’s inhabitants in rural areas and experiencing low rural broadband penetration, it’s unclear how the dialogue paper concludes that DBs wouldn’t be handicapped as in comparison with conventional banks on the subject of furthering monetary inclusion[9][10]. Certainly, the instance the paper describes because the goal buyer is that of a connoisseur café/ bakery included as a personal restricted firm in an city middle.

RBI’s Mandate – Defending Retail Depositors or Enterprise Capital traders?

Banking is essentially a low-risk enterprise. Banks work with two courses of traders, those that search low danger in trade for low returns and provide massive quantities of capital, and a smaller quantity that search a lot increased returns and are prepared to tackle a lot increased ranges of danger. In a financial institution, the primary are the depositors and the second are those who provide risk-capital. Nicely-managed banks then mix these two types of capital and make sure the mixture degree of danger that the financial institution takes on matches the expectations of its mixed investor group[11].

In opposition to this, the DB license seeks to make use of demand deposits (presumably retail, with permissions from the RBI) to experiment untested options and remedy for the MSME credit score hole and monetary inclusion hole within the nation. It due to this fact ignores the necessity for banks to be low-risk in character and supplies a direct channel for shifting losses from high-risk-high return-seeking fairness and Enterprise Capital (VC) traders to retail depositors, with out having demonstrated any proof of low-risk (low-NPA) origination. This could be unacceptable and goes in opposition to the essential tenets of banking.

Is the Digital Financial institution Fixing Issues Distinctive to Neo Banks?

Neo-banks are client dealing with entities which associate with incumbent banks to supply banking companies, like deposits and credit score, to customers. In offering these banking companies, Neo-banks depend on the stability sheet of the associate financial institution[12]. Via partnership with banks, these Neo-banks carry out the perform of a DB. Nonetheless, the dialogue paper identifies three main challenges to progress that Neo-banks at the moment face and posits that permitting them entry to a DB-like assemble might remedy for these issues[13]. The challenges recognized are[14]

  1. Restricted Income Potential – Neo-banks at the moment have solely 2 sources of income – 1) Channel associate charges and a pair of) Interchange on funds. The dialogue paper contends that the restricted sources of income threatens their viability and thus might hinder monetary inclusion.
  2. Potential Obsolescence of the Accomplice Financial institution Core Banking System (CBS) – Neo-bank choices are constrained by the product suite supplied by their associate banks. This limits their capability to customize merchandise for his or her clients.
  3. Excessive value of capital and no entry obstacles – Relying solely on fairness funding, Neo-banks face a excessive value capital for funding their operations. Moreover, the dearth of entry obstacles permits entry of all forms of actors and creates client safety danger.

It needs to be famous right here that not one of the challenges outlined by the dialogue paper stem from regulation or market failure. These are enterprise constraints which are current as a result of interaction of market forces. Taken along with the truth that these Neo-banks function primarily for a distinct segment client phase in city areas[15], it’s a stretch to contend that the demise of those Neo-banks would considerably hinder monetary inclusion, thus requiring regulatory intervention by RBI.

An in depth examination of the challenges additionally reveals that none of them are distinctive to Neo-banks and a few of them are fairly deceptive. As an illustration, the challenges of restricted income alternatives and excessive value of funding will not be true as there may be nothing stopping Neo-banks from making use of for an NBFC or financial institution license, which might permit them to get credit score, deposit and funds permissions. The NBFC license would permit them to entry capital that prices a lot decrease than fairness capital whereas additionally offering an extra income stream by way of provision of credit score. The rivalry within the dialogue paper that solely entry to low-cost funding can guarantee their sustainability is ill-founded at greatest provided that NBFCs have been extra worthwhile, in latest instances, than even banks[16]. The constraint imposed by the CBS of the associate financial institution is an operational challenge that may get resolved because the enterprise case for together with extra product codes turn into stronger. There is no such thing as a function for RBI right here. Lastly, the issues on client safety are largely mitigated as 1) Neo-banks don’t deal with buyer monies and therefore there may be low danger of fraud and a pair of) Neo-banks will probably be topic to due diligence and ongoing monitoring by their associate banks, as is already the case for all outsourced actions of banks. Points which have arisen on account of buyer safety can additional be mitigated if the RBI implements the suggestions of the RBI Committee on Digital Lending that seeks to convey underneath the regulatory radar all credit-related actions.

The dialogue paper additional supplies two use instances of DBs, neither of that are distinctive to solely DBs. The primary use case is that of Banking as a Service (BaaS). On this, DBs lease out their know-how stack to smaller banks, like cooperative banks, for whom shopping for the complete suite know-how stack can be unprofitable. One other instance of BaaS, that the paper illustrates, is the leasing out of the DB’s card issuance infrastructure to NBFCs that need to provide bank cards. Incumbent banks can even present these companies and at the moment there are situations of NBFCs partnering with banks to supply bank card companies. Moreover, Data Know-how (IT) corporations additionally present the choice to lease their CBS on a subscription foundation[17]. Equally, the use case introduced on Augmented Credit score Below-writing is only a description of the working of the Account Aggregator (AA) ecosystem and provides nothing new by way of specialised enterprise mannequin or further revenues for the DB.

The Licensing Regime and Regulatory Structure

The dialogue paper proposes a three-step licensing course of[18]. Within the first two steps, RBI vets all candidates and the chosen ones get a restricted DB license to function in a regulatory sandbox. The relaxations relevant within the regulatory sandbox is to be determined by RBI, consistent with RBI’s tips on regulatory sandbox. The RBI may even determine the success metrics to guage the efficiency of the licensees within the sandbox. Licensees who carry out satisfactorily are awarded a full stack DB license whereas these licensees not reaching the pre-defined metrics must exit by promoting their property and unwinding their liabilities as per the method laid down by RBI.

The regulatory structure[19] proposed by the dialogue paper brings parity between DBs and current banks on prudential and liquidity danger regulation. It additionally proposes that DBs have the identical degree of entry to infrastructure enablers, like Aadhar e-KYC, NEFT/RTGS, ATM community, DICGC and the Account Aggregator ecosystem, as incumbent banks. Because the operation of DBs will probably be nearly totally depending on know-how, the regulatory necessities embody further rules on DBs. For one, they would wish to have a number of of the controlling individuals within the entity to have a longtime monitor report in a number of fields like e-commerce, funds, cloud computing and the like. Secondly, there can be circumstances requiring ex ante technological preparedness and ex submit enterprise continuity planning.

The foremost relaxations, compared to incumbent banks, for DBs, are in minimal capital necessities and department mandate coverage. The minimal capital necessities for a DB are proposed as Rs. 200 Cr, equal to that of Small Finance Banks (SFBs), presumably as a result of DBs will not be anticipated to have any bodily branches, although no express rationale is given.

The dialogue paper means that the department mandates be interpreted in a progressive method to permit for banks to determine on the channel of supply of companies (with out presumably diluting the target of delivering banking companies to outlined unbanked areas). Nonetheless, the most recent Department Authorisation Coverage defines a Banking Outlet by way of the banking companies that it ought to present and doesn’t insist on a brick-and-mortar department[20] and to that extent, it already displays the suggestion made within the dialogue paper. Thus, it isn’t clear if the paper suggests this as a rest particular to DBs or whether it is to use to all banks.

Do DBs have any Utility?

It’s clear from the dialogue above that DBs don’t do something to push the envelope on monetary inclusion or systemic stability. The query then arises whether or not the DB assemble has any utility in any respect. A solution emerges if we have a look at the competitors side of licensing DBs. Although incumbent banks have entry to all of the technological options accessible to DBs, they haven’t adequately employed these options to raised customise their product choices to clients.   Provided that DBs can present all services and products being supplied by incumbent banks, they might probably improve competitors within the digital monetary companies house and power banks to speed up the adoption of technological options[21][22].  This might not solely present extra alternative for well-banked customers but in addition create an ecosystem the place banks compete to supply merchandise which are greatest suited to the client as an alternative of providing standardised merchandise as they’re doing at the moment.  


In contrast to differentiated banks, which have restricted banking features and thus decrease danger[23], DBs differ from incumbent banks solely within the channel of supply of companies and with low broadband penetration in our nation, it’s unclear how DBs would considerably enhance monetary inclusion. The whole proposal for the creation of DBs is constructed round growing the enterprise prospects of Neo-banks, and thus the exit valuations for VC traders, somewhat than round a stable case for growing monetary inclusion or lowering systemic danger within the banking sector. Particularly, the first motive of the proposal seems to be to permit Neo-banks, and different entities, to entry low-cost retail deposits and supply credit score with out having to undergo the prevailing licensing course of. Nonetheless, there may be some benefit in licensing DBs to speed up competitors within the digital monetary service house, which might show helpful to customers. Such a assemble will should be developed with out resorting to the necessity to remedy a monetary inclusion downside[24].  

[1] Part 4, Digital Banks – A Proposal for Licensing & Regulatory Regime for India, Dialogue Paper, Niti Aayog, November 2021

[2] Part 3, Ibid

[3] Part 4, Ibid

[4] Part 3, Ibid

[5] Lending corporations stare at 30% bounce in person acquisition prices, Pratik Bhakta, Financial Occasions, Might 1, 2019

[6] The small tenure of the loans implies faster churning of the loans thus necessitating acquisition of latest clients or repeatedly reaching out to current ones, Ibid

[7] See Exhibit 11, MSME Pulse, April 2020 – Transunion CIBIL and SIDBI

[8] Fixing India’s Banks: Making Banking Boring Once more, Nachiket Mor & Deepti George, BloombergQuint, January 7, 2021

[9] Rural broadband penetration in India is barely 29% in contrast the nationwide determine of 51%, see Broadband for Inclusive Improvement – social, financial and enterprise – Deloitte and CII report, Nov 2020. Moreover, utilization of web amongst MSMEs was abysmally low at solely 4%, see Digital Infrastructure and Coverage Initiatives within the MSME sector, Biswaraj Paul Choudhury, Dvara Weblog, April 15, 2019

[10] “Digital Banks: How can they be regulated to deepen monetary inclusion?” Slide Deck. Washington, D.C.: CGAP, Mehmet Kerse & Stefan Staschen, December 2021

[11] Why We Want Banks… And Getting Indian Banking Proper, Nachiket Mor & Madhu Srinivas, BloombergQuint, December 29, 2020

[12] Part 4, Digital Banks – A Proposal for Licensing & Regulatory Regime for India, Dialogue Paper, Niti Aayog, November 2021

[13] Part 5, Ibid

[14] Ibid

[15] Rising challenges for Indian neo-banks, Tarika Sethia, ET BFSI.com, August 4, 2021

[16] The ROA of NBFCs has been increased than banks for the previous 5 years – supply: The studies of the Pattern and Progress of Banking in India of the respective years and STRBI Desk No. 10 Financial institution Group Smart Chosen Ratios of Scheduled Industrial Banks

[17] From conversations with market individuals

[18] Part 7, Digital Banks – A Proposal for Licensing & Regulatory Regime for India, Dialogue Paper, Niti Aayog, November 2021

[19] Ibid

[20] Rationalisation of Department Authorisation Coverage – Revision of Tips, RBI Might 2017

[21] View: India’s banking revolution has began with out the banks, Andy Mukherjee, Financial Occasions, December 13, 2021

[22] Digital Banks: How can they be regulated to deepen monetary inclusion? Slide Deck. Washington, D.C.: CGAP, Mehmet Kerse & Stefan Staschen, December 2021

[23] Chapter 2.4, Report of the Committee on Complete Monetary Providers for Small Companies and Low Earnings Households, RBI, January 2014

[24] An analogous conclusion was arrived at by CGAP’s researchers, the place they conclude that “a broader query is whether or not it’s helpful to hyperlink monetary inclusion and digital banks in the best way it’s performed in a number of the nations. Selling monetary inclusion and serving the excluded and underserved might be performed by way of any current FSP license and digitization could possibly be a technique for a financial institution no matter whether or not it has a monetary inclusion focus or not”. Slide 25, Digital Banks: How can they be regulated to deepen monetary inclusion? Slide Deck. Washington, D.C.: CGAP, Mehmet Kerse & Stefan Staschen, December 2021

Cite this Merchandise:


George, D., & Srinivas, M. (2022). Response to Niti Aayog’s Dialogue Paper on “Digital Banks – A Proposal for Licensing and Regulatory Regime in India”. Retrieved from Dvara Analysis.


George, Deepti and Madhu Srinivas. “Response to Niti Aayog’s Dialogue Paper on “Digital Banks – A Proposal for Licensing and Regulatory Regime in India”.” 2022. Dvara Analysis.


George, Deepti, and Madhu Srinivas. 2022. “Response to Niti Aayog’s Dialogue Paper on “Digital Banks – A Proposal for Licensing and Regulatory Regime in India”.” Dvara Analysis.







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