Fragmented financial information creates both consumer harm and unclaimed wealth. Critically evaluate RBI's 2026 measures on AA interoperability and on bank deposits in the Consolidated Account Statement.
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RBI's 2016 Account Aggregator (AA) framework was meant to bring a person's financial data together on the basis of consent [2]. In practice the data is still split across about 15 AAs, banks and depositories [1]. RBI's October 2026 measures address this fragmentation, but they solve only part of the problem.
Harms of fragmentation
- Consumer harm: nobody has a single view of their assets, so advice and credit decisions rest on partial data [1].
- Unclaimed wealth: a deposit left untouched for 10 years moves to RBI's DEA Fund. Heirs often don't know the account exists [3].
Strengths
- Interoperability by 31 December 2026 creates a consolidated asset view [1], using the same networked approach as UPI in India's digital public infrastructure.
- Better-informed advice: asset managers, investment advisers and insurance brokers can use the data, but only with the customer's consent [1].
- Deposits in the CAS: the CAS issued by SEBI-regulated depositories leaves out bank deposits, which is "a significant gap" [1]. Adding them helps families trace deposits after a holder dies, before the money goes dormant.
- RBI–SEBI coordination is a step towards a single financial data architecture [1].
Limitations
- Weak consent: one blanket consent could now unlock a person's entire asset picture. Encryption protects the AA pipeline. It does not stop misuse by the data recipient, who may also be selling products.
- Narrow reach: the CAS only reaches people who invest through depositories. Households with forgotten savings accounts but no demat account are left out.
- Phased rollout: only banks already onboarded come first [1], so a CAS may show some of a person's deposits but not all.
- Old balances untouched: UDGAM only finds unclaimed deposits; claims still have to be made bank by bank [3]. The CAS stops new dormancy but does not reduce the existing DEA Fund balance.
Way forward
- Separate consent for each purpose, in line with the DPDP Act, 2023's purpose-limitation and consent-manager provisions [4].
- Link CAS data with UDGAM so that long-inactive deposits are flagged before they reach the 10-year mark [3].
- Publish the list of onboarded banks with a deadline for the rest, and regularly report what AA consents are used for.
Overall, the measures rightly treat consumer harm and unclaimed wealth as one problem: people cannot see all their money. Purpose-bound consent and wider reach to households would make interoperability a true public good. That would serve the Article 21 right to privacy and the goal of financial inclusion under SDG 8.10.
Sources
- 1The Hindu, "RBI to authorise inter-operability among NBFC-AAs" (news report, October 2026)about 15 AAs; deadline of 31 December 2026; data users only with consent; CAS leaves out bank deposits; phased onboarding of banks; RBI–SEBI step
- 2RBI, Master Direction – NBFC-Account Aggregator (Reserve Bank) Directions, 20162016 framework for consent-based aggregation of financial data
- 3RBI, Frequently Asked Questions on UDGAM Portal10-year transfer to the DEA Fund; UDGAM search tool; claims made with each bank
- 4Digital Personal Data Protection Act, 2023 (MeitY)purpose limitation; consent managers
Practice
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