Nasscom’s Feedback on RBI's Draft Master Directions on Cyber Resilience and Digital Payment Security Controls for Payment System Operators

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Nasscom’s Feedback on RBI's Draft Master Directions on Cyber Resilience and Digital Payment Security Controls for Payment System Operators

Garima Prakash

@GarimaP

July 3, 2023

Public Policy

In June 30, we submitted feedback to Reserve Bank of India (RBI), on Draft Master Directions on Cyber Resilience and Digital Payment Security Controls for Payment System Operators (draft Master Directions).

Our feedback included the following points:

Requirements must be made less prescriptive, to allow industry the flexibility to decide their preferred method of achieving the intended objective. For example, security testing of applications can be done by many ways, and not necessarily by qualified agencies only (as prescribed in the draft master directions).
Unnecessary duplication of compliance by the industry must be avoided. For example, reporting cyber security incidents to RBI within 6 hours of detection, is a duplication of the similar reporting that the industry does to CERT-In. This can be resolved by RBI coordinating access to this information with CERT-In.
Some requirements need clarifications, to facilitate compliance with certainty for the industry. For example, the responsibility of payment system operators towards unregulated entities’ compliance with the draft Master Directions with their mutual agreement, is not clear.
Onerous requirements must be made feasible. For example, the requirement to conduct Disaster Recovery drills half-yearly is onerous as it requires serious time and effort from the industry. This can be eased out by making it mandatory per-year, thereby bringing it in line with the industry’s practices.
Industry should be given more time to comply with the draft Master Directions. This is needed to ensure effective compliance with minimum disruption to digital payments.

To resolve for this, we have sought clarifications from the RBI and proposed alternatives which are intended to make the Master Directions more feasible while not compromising on the intended objective of ensuring cyber resilience in digital payments.

Our detailed comments on the Draft Master Directions on Cyber Resilience and Digital Payment Security Controls for Payment System Operators can be downloaded from below.

For more information, kindly write to garima@nasscom.in and policy@nasscom.in.

RBI CyberSecurity Fintech

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Garima Prakash

Manager, Public Policy and Government Affairs

Reach out to me for all things policy about e-commerce, international trade, export controls, start-ups and fintech