Technology Law Hotline: RBI Greenlights its FinTech Regulatory Sandbox! – Application window begins November 15, 2019

Posted by By at 7 November, at 18 : 46 PM Print

November 07, 2019


The Reserve Bank of India (RBI), India’s central bank, had earlier in August prescribed detailed guidelines and an operational framework on a regulatory sandbox to be set up in the fintech space. In a much-awaited move, the RBI announced on Monday that applications would be open from November 15 to December 15, 2019 for the first cohort of its regulatory sandbox. The theme for the first cohort is ‘Retail Payments’. As an indicative list of categories for inclusion within this theme, the RBI has mentioned “mobile payments including feature-phone-based payment services”; “offline payment solutions” and “contactless payments” as potential categories. While the first two categories are geared towards the enhanced adoption of digital payments across societal strata, the third is intended to enable small ticket payment transactions. Experimentation and testing of new products and services is likely to commence in the first half of 2020, as per media and industry sources.

The RBI has laid down various eligibility criteria for sandbox applicants, including:

  • The applicant should be a company incorporated and registered in India or a bank licensed to operate in India. Financial institutions constituted under a statute in India would also be eligible.
  • The applicant entity shall have a minimum net worth of INR 25 lakh (approx. USD 35,000) as per its latest audited balance sheet.
  • The promoters and directors of the entity should be ‘fit and proper’ as per the enumerated criteria.

NDA had analysed the draft regulatory sandbox framework in its hotline dated May 16, 2019.

– Aaron Kamath & Jaideep ReddyYou can direct your queries or comments to the authors

IFLR1000: Tier 1 for Private Equity and Project Development: Telecommunications Networks.
2020, 2019, 2018, 2017, 2014

AsiaLaw Asia-Pacific Guide 2020: Ranked ‘Outstanding’ for TMT, Labour & Employment, Private Equity, Regulatory and Tax

FT Innovative Lawyers Asia Pacific 2019 Awards: NDA ranked 2nd in the Most Innovative Law Firm category (Asia-Pacific Headquartered)

RSG-Financial Times: India’s Most Innovative Law Firm
2019, 2017, 2016, 2015, 2014

Chambers and Partners Asia Pacific: Band 1 for Employment, Lifesciences, Tax and TMT
2019, 2018, 2017, 2016, 2015

Benchmark Litigation Asia-Pacific: Tier 1 for Government & Regulatory and Tax
2019, 2018

Legal500: Tier 1 for Dispute, Tax, Investment Funds, Labour & Employment, TMT and Corporate M&A
2019, 2018, 2017, 2016, 2015, 2014, 2013, 2012

Who’s Who Legal 2019:
Nishith Desai, Corporate Tax and Private Funds – Thought Leader
Vikram Shroff, HR and Employment Law- Global Thought Leader
Vaibhav Parikh, Data Practices – Thought Leader (India)
Dr. Milind Antani, Pharma & Healthcare – only Indian Lawyer to be recognized for ‘Life sciences – Regulatory,’ for 5 years consecutively

Merger Market 2018:Fastest growing M&A Law Firm in India

Asia Mena Counsel’s In-House Community Firms Survey 2018:The only Indian Firm recognized for Life Sciences

IFLR: Indian Firm of the Year
2013, 2012, 2011, 2010

IDEX Legal Awards 2015: Nishith Desai Associates won the “M&A Deal of the year”, “Best Dispute Management lawyer”, “Best Use of Innovation and Technology in a law firm” and “Best Dispute Management Firm”


The contents of this hotline should not be construed as legal opinion. View detailed disclaimer.

This Hotline provides general information existing at the time of preparation. The Hotline is intended as a news update and Nishith Desai Associates neither assumes nor accepts any responsibility for any loss arising to any person acting or refraining from acting as a result of any material contained in this Hotline. It is recommended that professional advice be taken based on the specific facts and circumstances. This Hotline does not substitute the need to refer to the original pronouncements.

This is not a Spam mail. You have received this mail because you have either requested for it or someone must have suggested your name. Since India has no anti-spamming law, we refer to the US directive, which states that a mail cannot be considered Spam if it contains the sender’s contact information, which this mail does. In case this mail doesn’t concern you, please unsubscribe from mailing list.


Related Posts

Post Your Comment

You must be logged in to post a comment.

About Us

Nishith Desai Associates (NDA) is a research based international law firm with offices in Mumbai, Bangalore, Silicon Valley, Singapore, New Delhi, Munich and New York.


Mobile App


  • .
  • .
  • .