RBI Framework Implementation & Ongoing Support by N D Savla & Associates

Account Aggregators sit at the most sensitive point in the financial system. You don’t hold funds, but you handle consent-driven financial data. RBI treats this as a trust-heavy model, not a light-touch one.

AA compliance is continuous, technical, and closely monitored. Misses don’t stay invisible for long.

At N D Savla & Associates, we help NBFC–Account Aggregators set up, operate, and maintain full regulatory compliance under the RBI Account Aggregator framework.

What Is NBFC–Account Aggregator Compliance?

An NBFC–Account Aggregator is regulated by RBI and operates under a consent-based data-sharing model. The entity:

• Collects financial information only with explicit customer consent

• Shares data securely with Financial Information Users (FIUs)

• Does not store, process, or monetise customer data

• Must comply with strict technology, governance, and audit norms

Compliance goes far beyond filings. It extends into systems, controls, and real-time operations.

Key Compliance Requirements for NBFC–AAs

NBFC–AAs are required to comply with:

• RBI Master Directions for Account Aggregators

• Consent architecture and data privacy norms

• Information security and technology standards

• Periodic regulatory reporting

• Audit and governance requirements

This makes AA compliance a blend of regulatory, operational, and technical execution.

Our NBFC Account Aggregator Compliance Services

1. Compliance Readiness Assessment

We begin by reviewing:

• Existing AA operations and systems

• Consent flow and data-handling practices

• Regulatory gaps under RBI directions

• Governance and internal control framework

This identifies risks before they become inspection issues.

2. Policy & Framework Setup

We assist with drafting and reviewing:

• Consent management framework

• Data privacy and information security policies

• IT governance and risk management policies

• Customer grievance redressal mechanism

All documents are aligned with RBI and ecosystem expectations.

3. Regulatory Filings & Reporting

We support:

• Periodic RBI returns and disclosures

• Event-based reporting

• Updates related to directors, control, or operations

• Documentation for regulatory submissions

Accuracy and consistency are critical in AA reporting.

4. Audit & Inspection Support

We assist with:

• Preparation for system and compliance audits

• Coordination with auditors

• Closure of audit observations

• RBI inspection readiness

AA inspections focus heavily on process integrity.

5. Ongoing Compliance Monitoring

We help set up:

• Compliance calendars

• Periodic internal reviews

• Change management controls

• Management-level compliance reporting

This keeps compliance embedded, not reactive.

Who Needs AA Compliance Support?

• RBI-registered NBFC–Account Aggregators

• Newly licensed AA entities

• AAs scaling operations or onboarding new FIUs

• AAs preparing for RBI inspection or audit

If you hold an AA licence, continuous compliance is mandatory.

Why Choose N D Savla & Associates?

Account Aggregator compliance is specialised work.

• Experience with RBI-regulated NBFC frameworks

• Clear understanding of AA consent architecture

• Practical approach to regulatory expectations

• Coordination across legal, compliance, and operations

• Single-point accountability

We don’t treat AA compliance as routine NBFC work. It isn’t.