WS #238 Advancing financial inclusion through consumer-centric DPI

Summary

This panel discussion focused on Digital Public Infrastructure (DPI) and its potential to be consumer-centric, particularly in the context of financial inclusion. The conversation centered around experiences from Brazil, India, and other developing countries. Panelists discussed the benefits of DPIs, such as improved financial inclusion and increased competition in payment systems, as exemplified by Brazil’s PIX and India’s UPI.

Key challenges were highlighted, including the need for meaningful connectivity, cybersecurity concerns, and the importance of effective grievance redressal mechanisms. The Indian experience revealed issues with fraud detection, language barriers in customer support, and the need for better digital and financial literacy among users.

Panelists emphasized the importance of transparency, accessibility, and user-friendly design in DPI systems. They stressed the need for clear communication about consumer rights and timely dispute resolution. The discussion also touched on the role of regulators and financial institutions in ensuring consumer protection.

The importance of a systemic approach to DPI implementation was underscored, with suggestions for integrating different DPI components (identity, payments, data) from the early stages of development. Panelists also highlighted the need for proper safeguards and policy frameworks before implementing DPIs.

The discussion concluded with recommendations for improving consumer-centricity in DPIs, including regular audits, effective monitoring systems, and building DPIs “in the open” with public consultation and feedback mechanisms. Overall, the panel emphasized that while DPIs have the potential to be consumer-centric, careful design, implementation, and ongoing evaluation are crucial to achieving this goal.

Keypoints

Major discussion points:

– The benefits and challenges of Digital Public Infrastructure (DPI), particularly for payments systems like Brazil’s PIX and India’s UPI

– The importance of meaningful connectivity and digital literacy for DPI adoption and use

– Consumer protection issues related to DPI, including fraud, grievance redressal, and dispute resolution

– The need for safeguards, transparency, and multi-stakeholder involvement in DPI design and implementation

The overall purpose of the discussion was to examine whether and how Digital Public Infrastructure can be made consumer-centric, using examples from countries like Brazil and India to highlight both successes and areas for improvement.

The tone of the discussion was largely analytical and constructive. Speakers acknowledged the benefits of DPI while also critically examining its shortcomings, particularly around consumer protection. There was an overall sense of cautious optimism about DPI’s potential, balanced with calls for more safeguards and consumer-focused design. The tone became slightly more urgent when discussing fraud and consumer grievances, but remained solution-oriented throughout.

Speakers

– Luca Belli: Professor at FGV Law School, Director of the Center for Technology and Society at FGV

– Alexandre Barbosa: Researcher at the Weizenbaum Institute of the Berlin University of Arts

– Ritul Gaur: Policy Advisor for the Digital Impact Alliance (DIAL)

– Saroja Sundaram: Executive Director of Citizen Consumer and Civic Action Group

Additional speakers:

– Audience member: From Ethiopia, discussing digital ID development

– James (surname is missing): From Bloggers Association of Kenya

Digital Public Infrastructure (DPI) and Consumer-Centricity: A Comprehensive Analysis

This panel discussion explored the potential for Digital Public Infrastructure (DPI) to be consumer-centric, with a particular focus on financial inclusion. Drawing from experiences in Brazil, India, and other developing countries, the panellists examined the benefits, challenges, and necessary safeguards for effective DPI implementation.

Benefits and Implementation of DPI

The discussion began with an overview of DPI’s potential to increase financial inclusion and consumer welfare. Luca Belli, Professor at FGV Law School, highlighted three main categories of DPI: digital IDs, digital payments, and personal data consent managers. He emphasised that DPIs can help break monopolies and promote competition in financial services.

Successful implementations of DPI were showcased, with Alexandre Barbosa, Researcher at the Weizenbaum Institute, discussing Brazil’s PIX system. PIX has been instrumental in promoting digital payments in Brazil, with over 140 million users and processing more than 2 billion transactions per month. Barbosa highlighted PIX’s success in fostering financial inclusion, noting that it’s free for individuals and has low costs for businesses.

Similarly, Ritul Gaur, Policy Advisor for the Digital Impact Alliance, noted that India’s Unified Payments Interface (UPI) has enabled widespread digital transactions, constituting 80% of digital payments in India. UPI processes over 10 billion transactions per month, demonstrating its significant impact on India’s digital economy.

Challenges, Risks, and Consumer Protection in DPI Implementation

Despite the benefits, the panellists identified several challenges in DPI implementation and emphasized the need for robust consumer protection measures:

1. Meaningful Connectivity and Digital Literacy: Luca Belli stressed the necessity of meaningful connectivity for DPI adoption, highlighting that without proper infrastructure, the benefits of DPI cannot be fully realised. Saroja Sundaram, Executive Director of Citizen Consumer and Civic Action Group, pointed out that language barriers and lack of digital literacy hinder DPI usage, particularly in rural areas.

2. Cybercrime and Fraud: Ritul Gaur raised concerns about the increasing cyber crimes and frauds associated with UPI adoption in India. He described UPI as a “financial crime hotspot”, noting that the fraud helpline in India receives about 100,000 calls daily. This underscores the need for robust security measures and consumer education.

3. Consumer Redressal Mechanisms: Saroja Sundaram advocated for clear communication and user-friendly platforms for consumer redressal. She stressed the need for regular audits and monitoring of DPI systems to ensure they remain responsive to consumer needs. Sundaram also argued that ombudsman offices should be independent from regulators to ensure impartial handling of consumer complaints.

4. Online Dispute Resolution: Ritul Gaur suggested implementing online dispute resolution (ODR) for DPI-related issues, noting that this could provide a more accessible means of addressing consumer grievances without resorting to court proceedings.

Improving DPI Design and Implementation

The panellists offered several recommendations for improving DPI design and implementation:

1. Multi-stakeholder engagement: Alexandre Barbosa emphasised the importance of involving various stakeholders in DPI development and mentioned the UN DPI safeguards launched in September as a positive step.

2. Public consultation: Ritul Gaur suggested that DPI systems should be built openly with public consultation to ensure they meet user needs.

3. Digital literacy programmes: Saroja Sundaram called for customised digital literacy programmes for different consumer groups, recognising the diverse needs of various populations.

4. Proper safeguards: An audience member from Ethiopia stressed the need for appropriate safeguards and regulations to be in place before DPI implementation, citing their country’s experience with identity development driven by bank fraud concerns.

5. Integration of DPI components: Another audience member suggested integrating different DPI components (identity, payments, data) from the early stages of development to ensure interoperability.

Unresolved Issues and Future Considerations

The discussion left several issues unresolved, including how to effectively balance rapid DPI implementation with proper safeguards, address increasing cyber crimes, overcome language barriers in DPI usage and redressal mechanisms, and ensure the independence of ombudsman offices.

To address these challenges, suggestions included implementing a pre-legislative consultation policy for DPI-related regulations and creating a multi-stakeholder forum for ongoing discussions on DPI design and implementation.

Conclusion

The panel discussion revealed a cautious optimism about DPI’s potential to promote financial inclusion and improve consumer welfare. However, it also highlighted the need for careful design, implementation, and ongoing evaluation of DPI systems. The key takeaways emphasised the importance of meaningful connectivity, digital literacy, robust consumer protection mechanisms, and inclusive development processes in creating truly consumer-centric Digital Public Infrastructure. As countries continue to develop and implement DPI systems, addressing these challenges will be crucial for ensuring their success and maximizing benefits for consumers.

Luca Belli: update on our agenda. This session was supposed to be moderated by the… Oh yes, if we can also have the online participants on screen, that would be fantastic. So while we wait for the online participants to be put on screen, let me provide a little bit of update for our agenda. The session was meant to be moderated by the organizer of the session, Hannah Draper, that unfortunately had a last-minute impediment, so I will be taking over the moderation. My name is Luca Belle, I’m a professor at FGV Law School, where I direct the Center for Technology and Society at FGV. I was supposed to be a speaker of this panel, but I will also moderate it, together with me, Alessandro Barbosa, who is here with us in person, who is a researcher at the Weizenbaum Institute of the Berlin University of Arts, and with us online, we will have Saroja Sundaram, who is Executive Director of Citizen Consumer and Civic Action Group, which is a 39-year-old civil society organization based in Chennai, India, and then we will have Ritul Gaur, who is Policy Advisor for the Digital Impact Alliance, DIAL. Now, to start our conversation, let me just provide a little bit of introduction to the topic, and then I will directly provide a little bit of insight from Brazil and India, and then I will pass the floor to my colleague. and friend, Alessandro, and then we will have in order Ritu and then Saroja. What are we speaking about when we speak about digital public infrastructure, or DPIs, that became a very hot topic since the G20 in India last year, where the Indian presidency did a very interesting job in bringing to the international floor this concept of DPIs that have been implemented, debated, and studied in India for almost a decade in the context of the India stack, the digital transformation plan of India. And then they are spreading quite rapidly around the world with very good examples also from other countries, especially developing countries. We will see that Brazil has been not only experimenting, but implementing with a certain success some of these DPIs. And so DPIs are digital systems that are interoperable, they are designed to be supposedly secure, and they are built on open standards, on open specifications, so that they allow the provisions of public services, but also of private services, through this infrastructure, this digital infrastructure that is public. But also we will see that this conception of public really depends, and it is not universally defined what is public. And the difference that I’m going to illustrate between India and Brazil actually provide a very good illustration of this. Brazil has become very well known in DPI debates for PICS, it’s Digital Public Infrastructure for Payments. So usually there are three main categories. of digital public infrastructures, digital IDs, digital payments, and personal data consent managers. India has been experimenting and implementing them for several years, all three of them, and actually is now in the process of implementing another one, the online digital network for commons, the digital network for online commerce, which is a sort of grand bazaar online built on a digital public infrastructure. So we will see that there are several types of digital public infrastructure, but this specific workshop aims at discussing financial inclusion through DPIs. So the use of DPIs to build public infrastructure, digital public infrastructure for payments, right? And so here, my initial considerations that I’m blending with this introduction is that we need to have a systemic approach to this to understand how they function, what are their benefits, but also what are their limits? And I think that the cases from Brazil and India illustrates very well, and I wrote a paper about this last year for the G20 in India, for the T20, actually. And we co-authored with Hanna Draper, the organizer of this session, a T20 policy brief this year on digital public infrastructure, also stressing that the digital public infrastructure, especially DPIs for payment, could be very good example of good digital sovereignty. So of a country, but can also be not necessarily a country, could be also a regional or a municipal government, could even be group of individuals understanding the technology they’re using, developing it and regulating it in a way that is in the interest and put forward the interest, or at least should put forward the interest of the local community. Could be the municipal community, we have very good example in Brazil, for instance, the city where I live, Rio, has a very good… digital public infrastructure for taxis. There is a competitor of Uber, which is a digital public infrastructure for taxis. So you can hail a taxi through a digital public infrastructure built by a municipality. But again, here we start to, if we want to have a systemic approach, we start to understand that what is the first obstacle? To use DPIs, you need meaningful connectivity. If you are not connected, you cannot use a DPI. And I’m speaking about meaningful connectivity, not mere connectivity, because there is a lot of examples, especially in the global South, of entire countries and population that are connected through still today, through zero rating mechanism. So not meaningful connectivity, but it’s connected only through a very limited selection of apps that are sponsored, typically meta family of apps, social media. In this case, it is, even if you have the best possible DPI built by the government, people will not be able to access it. So the investment in it is thrown into the bin. And that is a very good, Brazil is a very good example of this, because 70% of the population that is now, or 80, that is now connected, almost 80 connected to the internet, only 20% of them, they have meaningful connectivity. And so when the PIX was launched during the pandemic, our digital public infrastructure for payment was created by the Brazilian Central Bank, which is an organ that understands very well these dynamics. So during the pandemic, when everyone was sort of locked down, WhatsApp wanted to launch WhatsApp payments ahead of our digital public infrastructure for payments. And the Brazilian Central Bank suspended the launch of WhatsApp payments for six months, because this would have created detrimental effect on privacy, data protection, competition, because having WhatsApp, a sort of monopoly of connectivity. everyone in Brazil is connected through WhatsApp, but very few people are connected to the rest. So it would have meant, if WhatsApp payment had been launched before our system PIX, that everyone would have used WhatsApp payment, no one would have used PIX. So understanding meaningful connectivity is key. And I think this is why when India adopted net neutrality regulations in 2016, they prohibited zero rating. Every people, especially at IGF circle, was discussing this as a tool, as a measure for net neutrality, for freedom of expression. But actually it was a digital sovereignty measure adopted by India, because they acknowledged that if they had allowed the entire population to be connected only to a certain specific set of apps, rather than the full internet, no one would have ever used both locally developed apps and also digital public infrastructure developed in India. So meaningful connectivity is key. And then when we adopt it, we can also foster competition and increase enormously consumer welfare. And here we enter the core of today’s discussion. Before PIX in Brazil, as in most other developing countries, online payments were only possible through Visa and MasterCard. So to foreign companies that charged between 3% and 5% per every transaction that happens. So the Brazilian consumer has had reverted into its pocket 3% to 5% Brazilian consumers and also sellers of goods or providers or services, they receive directly, thanks to this, 3% to 5% of what they pay for each transaction into their pockets. And this money is reverted to the national economy. And few people understand that also… So Visa and MasterCard, over the past 10 years, they have become big data companies. So most of their income does not come from the 3% to 5%, but comes from the personal data that they are collected about consumers and what they buy and when, and the profiling of them and building of artificial intelligence out of this. So why am I saying this? Because the benefit is not only a direct benefit for the consumer picks, it’s also an enormous competition boost that the competition authority would never have been capable of doing. It broke the duopoly of Visa and MasterCard and put into the picture a very new innovative solution that increased enormously consumer welfare and allowed everyone else in the field to build innovation on top of it. And this kind of competition measure would never have been possible through traditional regulation. Antitrust authority analyzing the duopoly and sanctioning, that would not have been possible. So we still also, we have to understand also DPIs. And I think that in India, this is a very present narrative. DPI is a tool of regulation. So not regulating by sanctioning, by creating a law, but regulating by creating an alternative. And this is a very powerful tool and aspect of DPIs. Of course there are limits. And again, here I don’t want to speak too much, but just to conclude, and a very final point that I want to stress is that the Brazilian experience in my perspective has improved the Indian payment, digital public infrastructure, UPI, because in India, this has been built and is currently still managed by a non-for-profit organization, the National Payment Corporation of India. And being not a public entity as in Brazil, which is managed by the Brazilian Central Bank, it’s much less transparent and accountable. If you’ve tried to file a request. to a freedom of access of information to a non-public entity, they will reply to you, I’m sorry, sir, this is not a public entity. So we are not obliged to reply to you. So if I in Brazil, I asked the Brazilian Central Bank to tell me, which data about me do you have? With whom you are sharing them? What are your security measures? They are obliged to reply to me. And if they don’t reply, I can sue them because they are a public body and they have an obligation to be transparent and accountable. But if in India, an Indian consumer asked to the National Payment Corporation of India, tell me which data about me do you have and with whom do you share them? They can perfectly reply to you, we are sorry, sir, this is not a public body. We are not bound by law to reply to you. So it’s very interesting to understand also the institutional context behind it. Of course, there is a rationale to have a non-for-profit building this. You can be suspicious of bureaucracies being very effective in building services. It’s not really their cup of tea. So they might have problem, but this also represents risks. Now, not to speak too much, let me give directly the floor to my friend, Alexandre Barbosa, to have his insight and then we can expand the conversation to our Indian friends.

Alexandre Barbosa: Thank you, Luca. Hello, everyone, both online and offline here present. Unfortunately, we don’t have here Hanna, the one who organized the session and also Jordan representing Co-Develop. Co-Develop is one of the main organizations behind this recent advancements of DPI worldwide. I mean, not speaking from a governmental perspective, but also from private and philanthropic services sectors. I will speak mainly regarding PICS in the Brazilian scenario, also considering all the dimensions beyond the design and the regulatory. aspects of payment systems. But I’d like to emphasise first this quite recent, as Luca clearly expressed here, boom of DPIs led by the G20 discussions in India, followed by Brazil this year, and likely to take place at South African presidency that just started a few weeks ago. So representing this IBAS, the India, Brazil and South Africa dialogues within this BRICS structure, kind of setting the scene for how DPIs are really taking place, especially in developing contexts. I think it’s clear how DPI brings to the table the role of the state when we think of technology development. And as an academic here, I must emphasise that despite at the policy international level, there is this, Rito is going to speak about it probably, like the sort of consensus around the three major DPIs that Luca mentioned. It’s worth highlighting the need to consider the physical and intangible material dimensions of infrastructure. I always want to talk about digital public infrastructure. So where this data is being processed, who controls this data processing infrastructures, where they are located, and so on. Indeed, BRICS succeeded, it enables payment 24×7, overcame debt cards and cash as the very first, the main payment method in Brazil. A few weeks ago, over 70% of the Brazilian population uses BRICS. It reached 10 days ago, 250 million transactions in a single day, accounting for over 120 billion Brazilian reais. And it’s worth mentioning that it is partially a result of a set of regulatory and policy measures within the National Council for Monetary Council that was kind of updating the financial system since the early 2010s. And I completely agree with Luca that it demonstrates that DPI can be popular, and in Latin America perspective popular here is mainly linked to massive. So it’s a massive, efficient, inclusive, and accessible alternative to private solutions without raising concerns about market concentration and the implication of the consumer rights and choices. And also regarding somehow to consumer rights, but more in a macro level, it’s the Brazilian Central Bank, the institution who develops and regulates PICS, stated that in September in Brazil, the Bolsa Familia beneficiaries, the major Brazilian social protection cash transfers program, which is recognized worldwide, the Brazilian Bolsa Familia beneficiaries spent three billion reais, actually three million, sorry, billion, indeed, in bets program softwares in August. So also thinking the extent to which these DPIs can enable better policies, and also a better comprehension of how the economic and socio-economic development of the country is taking place. Additionally, I’m not going too deep on that. It’s also a converging debate that we are taking place in FGV with Luca, within the CyberBRICS project. There is this convergence among DPIs and artificial intelligence that we can also think of the other way around. Also artificial intelligence properly. Yes. And also the way around artificial intelligence to DPI. Particularly in terms of embedding AI systems in a broader sense, also consider automated decisions, softwares. Last week, a Brazilian private bank, Nubank, announced that they’re gonna be the very first pigs with embedded AI, exactly to integrate, to interpret clients’ priorities and intentions and also enable these automated transactions. And also using AI to detect risky data patterns and so on, but without an explicit risk impact assessment of this combination of AI and DPI. So it’s something that we need to take a look in a forward implementation of the brand new, approved at the CNA, AI regulation last week. And also concluding here, I like to provide a reflection on the broader view on digital literacy and financial literacy. This convergence that also can be pushed and enabled through DPI implementations and regulations. When I speak here about digital literacy, I’m speaking in a broader sense. Brazil developed PNCC. It’s a national common curricular base that has among its main skills, competencies, pillars, both critical thinking and digital skills. skills, so not only being able to use a software or a digital tool itself, but knowing where this tool has been developed and who controls it, is also key here. And also, BMCC also encompasses different aspects of financial literacy, such as, it mentions different times in the document, like exploring historical, social and cultural dimensions of consumption, and so on, so there’s also room for thinking of this convergence of these two already in place that can be also adopted in other countries and scenarios, this convergence on financial and digital literacy through DPI regulations. But for this to actually take place, financial DPI promoters should also be promoters of educational DPIs, right? We also launched a T20 policy brief specifically regarding the need of developing these DPIs for education, not treating them as just sectorial application of DPI, but actually as key to promote this mention digital, critical digital literacy, and so on. And I have more here. Thank you, Luca.

Luca Belli: Excellent, Ale, and so we can now directly pass the floor to our online speakers. First, we have Ritul Gawbur. Please, Ritul, the floor is yours.

Ritul Gaur: Hi, Luca. Hi, Ale. Can you guys hear me?

Luca Belli: Yes, we hear you very well. Can we put also Ritul on screen? Can we put Ritul on screen?

Ritul Gaur: That’d be great.

Luca Belli: Thank you.

Ritul Gaur: Is it there? Should I start my address?

Luca Belli: You can start. We are not… We can hear you very well, our remote participation assistants are trying to have you on screen as well. Yes, we can see you now very well. Thank you. Go ahead.

Ritul Gaur: Perfect. Thank you so much. It’s unfortunate that I’m not there, but right there in the third row is my colleague Ibrahim. So if you guys feel that there is anything that I said, which is wrong or controversial, please catch him, and I’m sure he’ll have more answers. So I think I’m going to start my address on something very interesting I came across on Twitter, now on X few days back, is the co-founder of my first job, Think Tank, who recently tweeted that, who recently Xed that, I think there’s a need for a new consumer rights movement. Consumers have become so disempowered that there’s almost no way to seek address, and public policy has forgotten the consumer. And with that, it is so great to be on a panel where we’re actually talking about consumer and DPI in the same length and breadth. I’ve been in this world for over two years now, but haven’t really come across this in the same breadth. So I’m going to broadly talk about DPI first, and then dive into what does Indian DPI landscape looks like, particularly UPI, and then what does it mean to be a consumer in that sense. So Luca and Ale both talked about the benefits of DPI. We’ve seen how it has, in both Brazilian, Indian, Singaporean, a lot of African contexts, it has empowered users with giving them an identity. It has allowed them with the ability to transact in a fast and secure way. And most importantly, also allowed the storing and sharing of data and credentials to then avail a lot of other services. And unlike most other countries, India, Brazil, Singapore, etc. have done significantly well. But when we talk about India, it has not been an exactly easy journey, and much remains to be done in our digital journey. To lay out what remains to be done part of it, I think when we look at the Indian DPI story, we all know it works. And we’ve seen that well. But we don’t know what happens the day it does not work. The day my transaction fails, the day my authentication fails. We honestly do not know what is the grievance redressal mechanism because it’s layered through so many things. There’s the payment service provider, then there’s an app on top of it, and then there’s a grievance is done by somebody else. So we don’t really know what happens when this does not work. And I think it’s a big learning for countries who are designing who are just building out their systems. Think of it from get go that your population has enough faith that when things do not work out to be what really happens when it goes. So broadly laying out some challenges of UPI and what really does it constitute. UPI constitute 80% of digital payments in 2024 in India with billions of dollars being exchanged. It is fantastic. There’s a high amount of trust outside. There are ingenious solutions which includes small voice box that pops up every time a small payment is made. But at the same time, UPI is also a financial crime hotspot. And we do the extent that we don’t even know what we’re talking about here. There was a recent study by Dwara Research, a think tank in India, which highlighted the challenges in getting a grievance redress. And some of the findings were absolutely stark. Out of the six apps they surveyed, only four had a grievance redressal in-app grievance redressal mechanism. And India is a huge country with many, many languages. and only one out of four had tutorials or FAQs in their native languages. So essentially there’s a lot of grievance redressal mechanisms out there, but only in English for a population that does not understand English. So some very interesting finding was more men approach the grievance redressal mechanism than women. Apps almost have no support except in English, no vernaculars, all the FAQs are in English. Navigation issues. Grievance redress is hidden across multiple layers. It’s actually very difficult to find where it is. It’s not on your premium real estate where you can click and then actually go towards that. Documentation required. Sometimes the complaint mechanism is such that you can only lodge for a predefined complaint. You can’t really write your issue. So you have to pick from what’s out there. You can’t really write. So often it does not even capture all the issues and the modalities of it. You can’t do it via voice. You can’t do it via text, et cetera. Also severely constrained. Some of these apps didn’t even have a mechanism to track your ticket for the grievance that you had for. And now with this landscape, add on top of it that digital financial literacy is around 27% in India. UPI related frauds contribute to over 35% of the complaints to our National Crime Records Bureau. Can you believe it’s one third of our complaints to the National Crime Records Bureau is UPI related financial complaints. Incidents of domestic fraud in UPI rose by 85% as compared to the last financial year. So 85% jump. So, and I think if you look at it, it’s not just the payments have become easier. The payment system has become sophisticated. It is that the fraudsters have become really smart. Like they can clone a screen, they can clone an app. They can let you click on a particular thing from far away every day. In fact, in my hometown, in a tier 3 city, I hear somebody losing money, etc. So this has become all too very common. Now, I think it would be unfair to not talk about solutions. So I think from a very broad point of view, the two overall objectives on financial sector regulations are provide adequate consumer protection and protection against systemic risk. So consumer protection would depend on the speed with which fraud is detected, which is extremely important, and at the speed at which judicial process or whatever resolution arbitration takes place to make it work. And clearly, there have been some steps in India’s case which are working towards it. The central bank has integrated an ombudsman scheme which has integrated all ombudsmen so that if any complaint which is unresolved within 30 days, they can take it up to the ombudsman. In the payment system vision lineup, they have also introduced something called ODR, online dispute resolution, so that people don’t have to go to court for the smallest of the court cases because court cases in India are humongous. They go on for years and years, and people don’t really have an out if they actually get into a litigation affair. But sadly, much has not moved on this. There are a lot of other use cases for DPIs. As Ali was talking about, ONDC, which is essentially a big bazaar, has integrated online dispute resolution, but that has not happened in the case of UPI. There are various platforms, etc., which is launched by different ministries to just track and report what kind of financial crimes are happening. There is a national helpline that has been launched. It’s called 1930, where you can quickly report a fraud. And then there is a central bank that has also launched a central payment fraud information registry, which essentially keeps a track of all the frauds and then circulates it across all network participants. I think some updates on this, that the 1930 helpline has been getting 67,000 calls every day. 67,000 calls for frauds every day. The central bank tracker of the different complaints that the dashboard has over 1.1 million complaints on digital payment fraud, including for different channels. So I think there is some things which the state has been trying to do. There is no overarching, we don’t have a data protection rules out yet. We have a legislation, but there’s no rules out yet. So that hinders the consumer to actually avail that route. We don’t have a overarching financial sector regulation, which actually protects the consumer at the end of it, but we have these small tidbits of schemes, et cetera, which allows the consumer to be protected. Now, if you were to ask me that, what is it that the top three things that we should focus on in order to make consumer the focus of a robust financial DPI in India, I think the first would be work on ODR. Online dispute resolution is a very good mechanism to not go to court, but also find out a way out where the dispute can be resolved and consumer can get essentially a faster recourse to justice. Simplify user experience. I think all the apps, regardless of whichever app you use for UPI transaction, should have a similar kind of experience in reporting a fraud or financial transaction misplacing. Because if every app has a different mechanism, it’s very difficult for a large illiterate population, not illiterate, but large, not financially literate population to go and resolve for that out. So make sure it is a consistent experience throughout all apps. And I think more importantly than not, which is where I think a role of a lot of other players come into, the telecom, et cetera, improve fraud detection. If my way to actually. identify and report fraud is easy, then if there could be tags, etc. Other entities can also loop in and make it a robust way that fraud detection becomes easy. Crowdsourcing or fraud detection, suspicious activities can be detected and tracked and reported. I think that could lead for a robust financial DPI with the consumer at the center. That’s about it. Over to you guys.

Luca Belli: Thank you very much, Ritu. Very interesting points, especially regarding the booming cyber crimes and frauds in UPI, which clearly is an issue that must be addressed with further and more seriousness. Now, speaking about redress in terms of how can consumers try to cope with this kind of unfortunate situations and more, we have Saroja Sundaram, who has been dealing with this and other internet, digital literacy issues that can be also plugged into this discussion for some years. So please, Saroja, the floor is yours.

Saroja Sundaram: Thank you, Luca. I think my colleague, my friend Ritu has covered most of the concerns that we are facing on the ground. And as he had rightly mentioned, there are several positive aspects to this, which has been, which was covered by him, actually. So we recently did a study of around 2000 consumers, of users of digital financial services from the rural areas. So the findings were actually quite interesting, because most of the people, even street vendors today use UPI systems. So digital transactions that way has penetrated to the lowest level. And like everyone, seem to like, enjoy using it because of its convenience. But then there are some challenges as well. As pointed out by Ritul, I think it is across the platform and especially from rural areas, there are specific challenges. And most of the, like the country is, the citizens are from these areas. And so it’s very important for the regulator and the government agencies to actually look at the ground scenario on what is actually happening on the ground, how consumers are like the regulations, the policies that they frame, how far, how effectively it reaches the last mile is something that they need to assess, I feel, before they assess to actually see how they could strengthen implementation of their policies and their regulations so that consumers stand to benefit, even from the remotest area of the country stand to benefit. So Luka, as you pointed out, in India, again, connectivity, as you mentioned, mindful connectivity, meaningful connectivity is very important, I feel, because network connectivity in rural areas appears to be a challenge. So UPI transactions, the chances of double transaction, and then difficulty in getting the money back, all these are some of the challenges that we saw when we spoke with the consumers, because the internet connectivity is intermittent or very poor, so they have challenges there. And also the other concern, as Ritul pointed out, is about the redress mechanism. People don’t know where to complain, actually. Even the first step as to where to go into the app, they know to make a transaction. So it’s only like a QR code scan or just enter the number and just the transaction is through. But then to make a complaint, how to register a complaint and how to take it forward in case someone helps them with registering a complaint to take it to the next level in case they don’t get an address, what happens? And again, they don’t have the content in vernacular language. So that proves to be a challenge. So especially from a country like India with multiple languages, it’s very difficult for consumers actually. So that is another challenge that consumers don’t know how to deal with. And digital literacy is very limited. So we need to have customized and tailor-made literacy programs for consumers. Only then it will be, and it should be a continued engagement. And only then consumers will know what they are up to and how they can get issues addressed. In fact, I wanted to suggest, I want to suggest a few steps that should be taken to improve this situation actually from the various stakeholders. First is actually about accessibility and transparency. Consumer, when we talk about address mechanisms, they should be easy to understand and should be accessible to consumers. And transparency about the process, about the timelines, about the eligibility criteria, and all these should be readily available to the consumer so that it builds the trust, consumer trust. And user-friendly, the platforms should be user-friendly. That is also very important. So consumers should be easily, readily able to file complaints, track the status of their case, and receive guidance. And any kind of complaint, they should be able to upload or inform someone about the, not everyone will be familiar with the typing or writing. So they should be able to, there should be some other process, way by which they could actually record their complaint so that they are, and they should have this multilingual support as well. And clear communication, actually, provide consumers with clear communication about their rights, the steps in the redress process, and the outcomes should be available to the consumers. Similarly, timely and effective dispute resolution is very important. If that is not there, time-bound redressal, if it is not there, then it is going to be very difficult for consumers, which is what is happening today, unfortunately. And we need alternative dispute resolution also. Under the consumer protection law, we have mediation as an option for consumers to actually seek redress. So I think, and India, the Indian government, the Ministry of Consumer Affairs is actively promoting mediation in all the consumer commissions, the consumer courts. Mediation centers are required to be made available so that consumers can, say, get redress through mediation. Similarly, something like this online, some alternative dispute resolution mechanism should be available for consumers so that they are able to quickly seek redress for their issues. And compensation also. If the consumer is entitled to compensation or reimbursement, then that should also be processed quickly so that they are not harassed further. They have already lost their money and they should not be harassed further. We do have certain regulations in place. It’s not that there is nothing at all. We do have, when it comes to online transactions, there is the zero liability. There are situations where the consumer is totally responsible. Limited liability of consumers. All these are there in place, but then it has to be time bound, whatever the mechanisms. They should not be further harassed is what I feel. And I think the service providers, the financial institutions also have a role to play. They need to be actually more proactive to ensure that the citizens, if they face a problem, their issues are addressed. They should come forward to actually help consumers in such scenarios instead of actually immediately going on the defensive. This is what happens. So this is a challenge that needs to be addressed. And ombudsman. So in India, we have this body. It’s supposed to be an independent body, but unfortunately, it acts as an extended arm of the regulator. And so it’s like not every consumer will be able to easily approach the ombudsman’s office. So this is another thing. They have to be independent. They need to stay away from the regulator, and they should not be housed inside the regulator’s office, which intimidates a common man, actually. So I think that is something that we should have. They sit separately, and they handle issues separately so that consumers feel confident and trust the ombudsman’s office to go and register, escalate their complaint. You cannot register a complaint before the ombudsman directly. So you need to exhaust all the other avenues, like approaching the branch or the service provider directly. And then there is this internal ombudsman mechanism as well, where they can escalate their complaint. And then as a next step, they can approach this integrated ombudsman, who’s available for the consumers. But then it’s very important that they are independent so that there is no bias. And another important thing that I feel is very important is the monitoring mechanism that needs to be in place. I think it’s very important to continuously assess the effectiveness of redress mechanisms by collecting feedback from consumers. Consumers, when I say consumers, the different category of consumers, urban consumers, rural consumers, businesses, the bigger companies, and also the small vendors on the streets. To everyone, we should be talking and we should be taking feedback on a regular basis. These regular audits and monitoring can ensure that the system remains responsive to the evolving challenges and are approved to be consumer friendly. So yeah, so these are some of the suggestions I think I would like to state. And when it comes to digital literacy, I think there are several awareness programs that are happening, several awareness materials that the regulator has come out with. And it is available on their website. And some programs happen haphazardly here and there. But I think we need to actually move from this situation to a more robust, more dedicated, customized digital literacy programs should be developed targeting the different stakeholders so that consumers are aware. As Ritu mentioned, the frauds that are happening, like people are taken completely unaware. They don’t even know what is happening. just like that they lose their money. Then it’s a big struggle, and many a time you don’t get your money back. This is the ground reality. So I think it’s very important to see how we actually educate at least to that extent. There are situations that go beyond control, but then there are situations where it could be the consumer’s fault and where we educate them and they know their rights as a consumer. So I think we need to organize these workshops and training programs, which should be a regular phenomenon. And of course we have the online platforms today, social media, where we should be actually reaching out to consumers. And there are several other ways also, street plays and other for rural consumers through those medium, board games and things like that, where we can reach out to school children, where we actually educate them on digital literacy and also engage through social media and community as I mentioned, and also incorporation of real life scenarios. If we could give examples, real life stories on how people lost money in case studies, including them in our campaigns so that people know actually how you could be, one could be cheated in this space. So this actually will help. Tailor-made literacy programs are very important for consumers to know, for them to understand what is the concern around the space and how they need to be careful. Digital lending is another major problem actually. Many people are losing, being threatened actually. When we were talking to consumers, especially women, they offer 10,000, 20,000, It was a small money without any documents. So women who are running small business or for some family reason, for purpose, they go and take this money without informing any other family member. I happened to come across these two cases, where this lady, in one case, particular case, this lady took the money, 10,000 rupees, small amount only. She borrowed this money without any papers for some personal use. Later, what happened was the fellow started threatening her, telling her that he’ll be posting her photo on social media and all. And so he kept taking money from her. She paid up to 60,000 rupees for the 10,000 that she had taken. And then, beyond that also, when he started demanding money, only then she realized that she couldn’t do anything more. And she went and told her husband about it. And then they went to the police. And these things happen. So I think this space needs to be regulated. It has to be addressed. Because there are many, especially women, many people who are suffering because of this digital lending problem. So yeah, with this, I would like to conclude. And if there are any questions, I’ll be happy to take. Thank you.

Luca Belli: Thank you very much. Thank you very much for this. And I’m sure there will be questions or considerations from the audience. We have here people in the floor that have been with us for the entire workshop. So if we have any considerations, questions, or even personal experiences that you would like to share to understand to what extent DPI can be consumer-centric or are not, or even to bring examples from your own countries, this is the moment, actually, where you can do so. So if you want, if anyone in the audience here in the room wants to contribute to the discussion, please. free to raise your hand and add your two cents or two rupees. Yes, sir. Yes, we have. Can we bring a mic to this gentleman here? Thank you.

Audience: Thank you. Thank you. Thank you for the nice discussion in the nice presentations. I really like the way both speakers have managed to frame the consumer centricity demand of DPI and look at the experience of Brazil in terms of picks as well. It’s quite solid. Many countries in Africa are looking at the experience of PICS, which is, you know, the public part of public driven DPI development process, which is quite essential in terms of putting proper safeguards on time on from the onset. Some countries are actually going deeper into the DPI development without proper safeguards being in place, policy and regulatory processes being in place. So PICS has a lot to learn from that, a lot to share from that perspective. One potential practice for consumer centricity of DPI in Africa, and I’d like to relate to the country that I come from, which is Ethiopia, in the process of identity development, right? One of the driving factors for ID development, which gave it an extra momentum for consumer centricity is the level of identity fraud available or identity fraud attacks that banks in the country were facing. The major challenge being the lack of digitally verifiable identification system in Ethiopia, has led to the actual creation of a digital identification process. And the amount of money the banks were losing annually was quite huge to the extent that it has driven them to get together and invest in the early enrollment technology that was supportive of the government’s partnership, the government’s plan for digital identification. development. And this has actually been a sign of a commitment and be a collaborative work between public private partnership for DPI development, and it’s a solid case. Now, still, it has a challenge of having a proper safeguard. But for me, it’s a major indicator of consumers, consumer centricity whereby identity fraud is not only affecting the banks but also account holders and transactors. And thereby creating a very fertile ground to create consumer centric digital public infrastructure system. But the challenge being and then this is something that I would like the other speakers to actually also address is the fact that DPI approach process. So, usually there’s a single track siloed approach of implementing DPIs without putting proper safeguards and that’s one of the major challenge ID systems are facing at this point in time, payment systems are facing at this point in time. So there’s a need to create integration there’s a need to create interoperability, but also there’s a need to create from the onset from the beginning at the design stage issues related to safeguard so for me, it’s just a comment and a question. The first is the fact that a yes there are multiple examples of the consumer centricity from the design from the intention of DPI itself. But then again, there’s a need to actually bring all these DPI components together ID payment data from the early onset on onwards to make sure that they, they integrate and work closely and in partnership. Thank you.

Luca Belli: Those are excellent comments. Do we have any other other here otherwise, as we, yes we have another gentleman here. Yes, please go ahead. Introduce yourself. Yes.

Audience: My name is James from bloggers Association of Kenya, and yeah, I’m from Kenya. I, I just want to make a contribution it’s a, it’s actually a comment. It’s, it’s quite interesting that you’re having this conversation about DPS being consumer centric. consumer-centric because we have an opposite experience in Kenya and that’s what we’ve actually been trying to get the government to actually see basically the point of having something consumer-centric because what is happening is, so for instance, the president will go out there and let’s say go to Google or go to any IT company, ETC, or maybe like one of the ministers is approached and then they have what is called a top-down approach. So you just have a solution, just dump it on you and it doesn’t work for anyone. And then also something else, instead of going, let’s say the Brazil way where the, let’s say the regulator comes up with an idea and builds it from the ground up, you know, they just, I don’t know how to say this, but they just dump this thing that they don’t know if it’s going to work and then now they start putting, you know, they start putting sort of clusters as you go along. The whatever, I don’t know whether it’s the gentleman or the lady who said that, you know, customer care and being able to have your issues sorted is one of the ideal ways of building a customer, or rather consumer-centric DPI. So when it’s top-down, it’s even worse because now when you think about it, they actually building, they’re actually using a system that they have not involved any of the stakeholders and most importantly, the. public. And so what you have is just something that doesn’t work. From, you know, from a general perspective, I feel like maybe with DPS, and especially for countries that are starting to adopt this, like us, like Kenya, I feel like what you need to start with like policy, you have a policy in place. And then I’ll build from there.

Luca Belli: Thank you. Thank you very much for this excellent comment. Actually, it allows me to provide just a little bit of clarification. The I want to make clear that the goal of the panel is to assess whether and how DPS can be consumer centric, but it was none of the speakers intention to argue that they are by default consumer centric. So this last comment is actually very useful to clarify that they can be. And I believe that probably the Brazilian experience is one of the most of the closest to be consumer centric simply because it was it is one of the most recent. And so it could learn also from the mistakes of other I know that in Kenya, you have NPESA. It is very similar to the Brazilian peaks, but it’s also very different. And I also understand some of the difference maybe on how it has been proposed and implemented. So our colleagues from the remote assistance remind us that we have to to wrap up. So I would like to give to our my fellow panelists a final moment to provide their final thoughts. Maybe some some provocative remarks, final remarks in one minute, or some some hope for the future. Feel free to use the last minute that you have at your disposal as you want. So maybe we can go with Ale and then Rito and Sraja.

Alexandre Barbosa: Thank you, Luca. Thank you for the reflections as well. Quite quite quickly. Definitely, there’s the Brazilian experience, the Indian experience, it should not be like just replicated elsewhere. Brazil has a long trajectory in terms of civil society, engagement in digital rights and internet governance, indeed the multi-stakeholder and so on. And we need to think of the design of DPI is at least at two levels. One is this customization as the financial services provider level, but also at the architecture level. PIX is divided mainly into two. One’s the instant payment system, what it was built in already existing financial infrastructure, and also the decentralized identifier, which enables this portability of keys and so on. But I don’t have time to dig on that. And I also like to emphasize that PIX also has among its structure, the forum PIX, the PIX forum, which is also a multi-stakeholder, it’s space for deciding, discussing decisions upon the design and appreciate again the time here and take a look in the UN DPI safeguards that was launched just in September. It provides also interesting insights. Thank you.

Luca Belli: Thank you very much, Alessio. We can go to Ritu and then Suraj.

Ritul Gaur: Hi, I just wanna make one small point and thank you, Brian, for actually pointing that out about the safeguards thing. I think for any government looking forward to build, one of the most important thing is to build it in open. Every document, everything, if it’s published in open, even if it’s pricing, even if it’s small tweaks in regulations, et cetera, as much as you can allow the documents to be out and open, you allow the civil society to analyze, criticize, et cetera, and then make the feedback box welcome and open. I think building it open is something which is very critical. In India, in 2014, they launched something called PLCP. which is pre-legislative consultation policy for any legislation, any regulation, it has to be out in public for public comments for a minimum of 30 days. Otherwise, it cannot pass. So I think something like that, which if you’re planning to build, because it’s difficult to involve people like the scale of which democracies work in every small decisions. But if you can, at least build it in open, I think you allow for a greater amount of transparency in the system. So yeah, that’s it. Excellent. Thank you so much. This was a great experience.

Luca Belli: Saraju, please. Yeah.

Saroja Sundaram: So I think we need to have an effective monitoring system in place, especially looking at vulnerable consumers, the concerns, like if you’re going to have regular audits, do regular audits, then we will know where we stand in terms of being the sense the government agencies, the regulator, where they stand in terms of the implementation of their policies. And this will stand as a feedback for them to actually improve their system so that consumers stand to benefit. So yeah, this is what I think we need most.

Luca Belli: Fantastic. And I think with this word of optimism and hope for the future, we can close this panel. Thank you very much to all the participants. Very good discussion and hope you have an excellent IGF. Bye-bye. Thank you. Bye-bye.

Agreement Points

DPIs can promote financial inclusion and improve consumer welfare

Luca Belli

Alexandre Barbosa

Ritul Gaur

DPIs can increase financial inclusion and consumer welfare

Brazil’s PIX system has been successful in promoting digital payments

India’s UPI system has enabled widespread digital transactions

The speakers agree that Digital Public Infrastructure (DPI) systems like Brazil’s PIX and India’s UPI have successfully promoted financial inclusion and improved consumer welfare by enabling widespread digital transactions and reducing costs.

Consumer protection and redressal mechanisms are crucial for DPI systems

Ritul Gaur

Saroja Sundaram

Online dispute resolution should be implemented for DPI-related issues

Clear communication and user-friendly platforms are needed for consumer redressal

Regular audits and monitoring of DPI systems are necessary

Ombudsman offices should be independent from regulators

Both speakers emphasize the importance of effective consumer protection measures, including dispute resolution mechanisms, clear communication, and independent oversight for DPI systems.

Similar Viewpoints

The speakers agree that meaningful connectivity and digital literacy are essential for effective DPI adoption and usage, particularly in rural areas and among diverse populations.

Luca Belli

Ritul Gaur

Saroja Sundaram

Meaningful connectivity is necessary for DPI adoption

Language barriers and lack of digital literacy hinder DPI usage

Customized digital literacy programs are needed for different consumer groups

Unexpected Consensus

Importance of multi-stakeholder engagement in DPI development

Alexandre Barbosa

Ritul Gaur

Audience

DPI development should involve multi-stakeholder engagement

DPI systems should be built openly with public consultation

Top-down DPI implementation without stakeholder involvement can be problematic

There was an unexpected consensus among speakers from different backgrounds on the importance of involving multiple stakeholders, including civil society and the public, in the development and implementation of DPI systems. This agreement highlights a shared recognition of the need for inclusive and transparent processes in DPI development.

Overall Assessment

Summary

The main areas of agreement include the potential of DPIs to promote financial inclusion and improve consumer welfare, the need for effective consumer protection mechanisms, the importance of digital literacy and meaningful connectivity, and the value of multi-stakeholder engagement in DPI development.

Consensus level

There is a moderate to high level of consensus among the speakers on the benefits and challenges of DPI implementation. This consensus suggests a shared understanding of the potential of DPIs to drive financial inclusion and economic development, while also recognizing the need for careful implementation, consumer protection, and inclusive development processes. The implications of this consensus are that future DPI initiatives are likely to focus on addressing these shared concerns, potentially leading to more robust and user-centric systems.

Different Viewpoints

Approach to DPI implementation

Luca Belli

Ritul Gaur

Audience

DPIs can increase financial inclusion and consumer welfare

Cyber crimes and frauds are increasing with UPI adoption in India

Top-down DPI implementation without stakeholder involvement can be problematic

While Luca Belli emphasizes the benefits of DPIs for financial inclusion and consumer welfare, Ritul Gaur highlights the increasing cyber crimes and frauds associated with UPI adoption in India. The audience member points out the problems with top-down DPI implementation without proper stakeholder involvement.

Unexpected Differences

Institutional structure for DPI management

Luca Belli

Saroja Sundaram

DPIs can help break monopolies and promote competition

Ombudsman offices should be independent from regulators

While discussing the benefits of DPIs, Luca Belli focuses on their ability to break monopolies and promote competition. Unexpectedly, Saroja Sundaram raises a concern about the institutional structure, arguing for independent ombudsman offices. This highlights a potential tension between promoting competition and ensuring effective oversight.

Overall Assessment

summary

The main areas of disagreement revolve around the implementation approach of DPIs, the balance between benefits and risks, and the institutional structures needed for effective oversight and consumer protection.

difference_level

The level of disagreement among the speakers is moderate. While there is general agreement on the potential benefits of DPIs, there are significant differences in perspectives on implementation strategies, risk management, and governance structures. These disagreements highlight the complexity of implementing DPIs effectively and the need for careful consideration of various stakeholder perspectives to ensure successful and inclusive digital infrastructure development.

Partial Agreements

Both speakers agree on the need for effective consumer redressal mechanisms, but they propose different approaches. Ritul Gaur suggests implementing online dispute resolution, while Saroja Sundaram emphasizes clear communication and user-friendly platforms.

Ritul Gaur

Saroja Sundaram

Online dispute resolution should be implemented for DPI-related issues

Clear communication and user-friendly platforms are needed for consumer redressal

Similar Viewpoints

The speakers agree that meaningful connectivity and digital literacy are essential for effective DPI adoption and usage, particularly in rural areas and among diverse populations.

Luca Belli

Ritul Gaur

Saroja Sundaram

Meaningful connectivity is necessary for DPI adoption

Language barriers and lack of digital literacy hinder DPI usage

Customized digital literacy programs are needed for different consumer groups

Key Takeaways

Digital Public Infrastructure (DPI) can promote financial inclusion and consumer welfare when implemented effectively

Successful DPI implementations like Brazil’s PIX and India’s UPI have enabled widespread digital transactions

DPIs can help break monopolies and promote competition in financial services

Meaningful connectivity and digital literacy are crucial prerequisites for DPI adoption

Consumer protection and robust redressal mechanisms are essential for DPI success

Multi-stakeholder engagement and open development processes are important for effective DPI design and implementation

Resolutions and Action Items

Implement online dispute resolution mechanisms for DPI-related issues

Conduct regular audits and monitoring of DPI systems

Develop customized digital literacy programs for different consumer groups

Ensure DPI systems are built openly with public consultation

Unresolved Issues

How to effectively balance rapid DPI implementation with proper safeguards and regulations

How to address increasing cyber crimes and frauds associated with DPI adoption

How to overcome language barriers in DPI usage and redressal mechanisms

How to ensure independence of ombudsman offices from regulators

Suggested Compromises

Implement a pre-legislative consultation policy requiring public comments before passing DPI-related regulations

Create a multi-stakeholder forum for ongoing discussions on DPI design and implementation

Brazil has become very well known in DPI debates for PICS, it’s Digital Public Infrastructure for Payments. So usually there are three main categories of digital public infrastructures, digital IDs, digital payments, and personal data consent managers.

speaker

Luca Belli

reason

This comment provides a clear framework for understanding different types of DPIs, which helps structure the rest of the discussion.

impact

It set the stage for more detailed exploration of DPIs in different countries, particularly Brazil and India.

The Brazilian Central Bank suspended the launch of WhatsApp payments for six months, because this would have created detrimental effect on privacy, data protection, competition, because having WhatsApp, a sort of monopoly of connectivity.

speaker

Luca Belli

reason

This example illustrates how government regulation can protect consumer interests and promote competition in the face of powerful tech companies.

impact

It sparked discussion about the role of government in regulating DPIs and protecting consumer interests.

UPI constitute 80% of digital payments in 2024 in India with billions of dollars being exchanged. It is fantastic. There’s a high amount of trust outside. There are ingenious solutions which includes small voice box that pops up every time a small payment is made. But at the same time, UPI is also a financial crime hotspot.

speaker

Ritul Gaur

reason

This comment highlights both the benefits and risks of DPIs, providing a balanced perspective.

impact

It shifted the conversation to focus more on the challenges and risks associated with DPIs, particularly in terms of consumer protection and fraud.

We need to have customized and tailor-made literacy programs for consumers. Only then it will be, and it should be a continued engagement. And only then consumers will know what they are up to and how they can get issues addressed.

speaker

Saroja Sundaram

reason

This comment emphasizes the importance of consumer education in making DPIs truly consumer-centric.

impact

It broadened the discussion to include the need for consumer education and literacy programs as a key component of successful DPI implementation.

Some countries are actually going deeper into the DPI development without proper safeguards being in place, policy and regulatory processes being in place.

speaker

Audience member

reason

This comment from an audience member brings attention to the risks of implementing DPIs without proper safeguards.

impact

It reinforced the importance of regulatory frameworks and safeguards in DPI implementation, leading to further discussion on this topic.

Overall Assessment

These key comments shaped the discussion by providing a comprehensive overview of DPIs, their benefits, and challenges. The conversation evolved from a general introduction to DPIs to a more nuanced exploration of implementation challenges, consumer protection issues, and the need for regulatory frameworks. The comments highlighted the complexity of implementing DPIs in different contexts and emphasized the importance of consumer-centric approaches, including education and robust grievance redressal mechanisms. The discussion also touched on the role of government regulation in ensuring fair competition and protecting consumer interests in the face of powerful tech companies.

How can online dispute resolution (ODR) be effectively implemented for UPI transactions?

speaker

Ritul Gaur

explanation

ODR was suggested as a key solution to address consumer grievances without going to court, but its implementation for UPI is not yet realized.

How can the user experience for reporting fraud and financial transaction issues be simplified and standardized across all UPI apps?

speaker

Ritul Gaur

explanation

Inconsistent complaint mechanisms across apps make it difficult for users, especially those with limited financial literacy, to seek redress.

What methods can be developed to improve fraud detection in UPI transactions, potentially involving multiple stakeholders like telecom providers?

speaker

Ritul Gaur

explanation

Improving fraud detection is crucial given the high incidence of UPI-related frauds reported to the National Crime Records Bureau.

How can digital literacy programs be customized and tailored for different stakeholder groups, especially in rural areas?

speaker

Saroja Sundaram

explanation

Customized digital literacy programs are needed to address the specific challenges faced by different groups of consumers, particularly in rural areas with limited connectivity and literacy.

How can the independence and effectiveness of the ombudsman system for addressing consumer complaints be improved?

speaker

Saroja Sundaram

explanation

The current ombudsman system is perceived as an extended arm of the regulator, potentially intimidating consumers and limiting its effectiveness in resolving disputes.

What mechanisms can be put in place to continuously assess the effectiveness of redress mechanisms through consumer feedback?

speaker

Saroja Sundaram

explanation

Regular audits and monitoring based on diverse consumer feedback are needed to ensure the system remains responsive to evolving challenges.

How can proper safeguards and policy/regulatory processes be implemented from the onset of DPI development?

speaker

Audience member (unnamed)

explanation

Some countries are developing DPIs without proper safeguards in place, which could lead to issues later on.

How can integration and interoperability between different DPI components (ID, payment, data) be ensured from the early design stages?

speaker

Audience member (unnamed)

explanation

There’s a need to bring all DPI components together from the early onset to ensure they integrate and work closely in partnership.

How can a bottom-up, stakeholder-inclusive approach to DPI development be encouraged, especially in countries where top-down approaches are prevalent?

speaker

James (audience member)

explanation

Some countries are implementing DPIs without involving stakeholders or the public, leading to systems that don’t work effectively for consumers.