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Submission on Draft Amendments to the Aadhaar Authentication for Good Governance (Social Welfare, Innovation, Knowledge) Rules, 2020
Submission on Draft Amendments to the Aadhaar Authentication for Good Governance (Social Welfare, Innovation, Knowledge) Rules, 2020

May 11, 2023

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On May 5, 2023, Nasscom submitted comments to the Draft Amendments to the Aadhaar Authentication for Good Governance (Social Welfare, Innovation, Knowledge) Rules, 2020. These propose to allow entities, other than govt departments, to undertake Aadhaar authentication if some conditions are met. Please find the proposed amendments here, and our blog summarising the amendments here.

Our feedback is as follows:

On Rule 3(1)(aa):

  1. We have sought for a more precise definition of the proposed purpose of "promoting ease of living and enabling better access to services for them" under draft Rule 3(1)(aa), including clear illustrations and examples of what is covered.
  2. We recommend a simplified process for entities seeking to use Aadhaar authentication for permitted use-cases, in addition to the current application-based process.

On Rule 4:

  1. We recommend using "requesting entity" instead of "any entity" in Draft Rule 4(2).
  2. We have sought for a more precise definition of the term "interest of the State" under Rule 4.
  3. We recommend that proposals be forwarded directly to the UIDAI by the concerned Ministry/Department. The current four-step process proposed in Rule 4 can be simplified by removing step 2, which would reduce administrative overhead.
  4. We have sought for maximum time limits for evaluation of proposals to be followed by Ministries/Departments for clarity.
  5. We suggest the inclusion of a feedback mechanism for rejected proposals.
  6. We recommend a single window system for applying entities to submit proposals to relevant and multiple Ministries/Department in one go, track the status of their proposals, and access a dedicated helpline for assistance. This would streamline the evaluation and approval process for the Government and ensure a consistent approach across sectors, accommodating any parallel administrative processes on Aadhaar authentication.
  7. We suggest introducing new guidelines on proposals from non-governmental entities under the proposed Rule 4(2), with standardised forms, guidance on preparation and evaluation, compliance with the Aadhaar regulatory framework, and protection of citizens' rights. The guidelines should also include conditions for applications for Yes/No authentication versus e-KYC, and public consultation should be conducted before finalising the guidelines.

Detailed submission is attached for your reference. For more information, kindly write to varun@nasscom.in or priyanshi@nasscom.in with a copy to policy@nasscom.in.   


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priyanshi
Senior Associate, Public Policy and Government Affairs

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