Digital Rupee, Fintech and Account Aggregators: Notes
Banking awareness notes on the Digital Rupee: the CBDC pilots, the RBI Act amendment, NPCI systems, Account Aggregators and the digital lending guidelines.
By GK24 Editorial Team· Published · 6 min read

The Digital Rupee, written e₹, is the Reserve Bank of India’s Central Bank Digital Currency, that is the Indian rupee issued in digital form as legal tender. Around it sits a wider world of fintech — the payment systems, digital lending rules and data-sharing frameworks that have reshaped Indian banking since 2016. Banking examinations ask this topic every year, and the questions are precise: the Act that was amended to allow a digital rupee, the dates the two pilots began, the difference between a CBDC and the Unified Payments Interface, and the three roles in the Account Aggregator framework. This note sets out those facts in the order an examiner uses them.
What a Central Bank Digital Currency is
A CBDC is sovereign currency in digital form, issued by the central bank and appearing as a liability on its balance sheet. Because it is legal tender it is accepted for the discharge of any debt, it carries no credit or liquidity risk for the holder, and it is exchangeable one for one with cash and with bank deposits. It is not a cryptocurrency: a cryptocurrency is issued by no sovereign, is not legal tender and has no fixed value, while the digital rupee is issued by the Reserve Bank and is always worth one rupee.
The legal basis is the point most often tested. The Finance Act, 2022 amended Section 2 of the Reserve Bank of India Act, 1934 to widen the definition of a bank note so that it includes a note issued in digital form, and the Union Budget for 2022-23 announced that the Reserve Bank would introduce the digital rupee. The Reserve Bank had published its Concept Note on Central Bank Digital Currency in October 2022, setting out the motivation, the design choices and the risks.
The two digital rupee pilots
| Feature | Wholesale, e₹-W | Retail, e₹-R |
|---|---|---|
| Pilot began | 1 November 2022 | 1 December 2022 |
| Who uses it | Select banks and financial institutions | Public, through participating banks |
| First use case | Settlement of secondary market transactions in Government securities | Person-to-person and person-to-merchant payments |
| Design | Account-based | Token-based, held in a digital wallet |
| Denominations | Not applicable | Same as existing coins and notes |
Both pilots use the indirect or intermediated model: the Reserve Bank issues the digital rupee, and banks distribute it, open the wallets and handle customer service, exactly as they distribute cash. The digital rupee earns no interest, which is a deliberate design choice; if it paid interest, savers would move money out of bank deposits and banks would have less to lend. Other features the Reserve Bank has tested are programmability, so that a payment can be tied to a purpose such as a subsidy or a tenanted-area loan, and offline functionality, so that a payment can go through where there is no network.
Digital rupee against UPI and against cash
Students confuse the digital rupee with the Unified Payments Interface, and papers exploit the confusion. UPI is a payment system: it moves money that already sits as a deposit in a bank account, and the transfer is settled later between the banks. The digital rupee is money itself, central bank money, so when it passes from one wallet to another the payment is final at once and no interbank settlement follows. Against cash, the digital rupee has the advantage of costing nothing to print, store or transport, and the disadvantage of needing a device; cash remains fully anonymous, while a digital rupee transaction leaves a record with the issuing system, which is why the Reserve Bank has spoken of "reasonable anonymity" for small amounts.
The payment systems that fintech is built on
The National Payments Corporation of India is the umbrella organisation for retail payments, set up in 2008 under the guidance of the Reserve Bank and the Indian Banks’ Association, incorporated as a not-for-profit company under what is now Section 8 of the Companies Act. It operates the Unified Payments Interface, launched in 2016, along with the Immediate Payment Service of 2010, RuPay, the National Electronic Toll Collection system behind FASTag, the Bharat Bill Payment System, the Aadhaar Enabled Payment System and the National Automated Clearing House. RTGS and NEFT are operated by the Reserve Bank itself and both are available round the clock. The enabling law for all of them is the Payment and Settlement Systems Act, 2007.
Three smaller products are asked by name. e-RUPI, launched in 2021, is a prepaid, person-specific and purpose-specific electronic voucher delivered as an SMS or QR code. UPI 123PAY, launched in 2022, allows UPI payments from a feature phone without the internet. UPI Lite is an on-device wallet for small-value payments that works without a PIN for each transaction.
The Account Aggregator framework
An Account Aggregator is a consent manager for financial data. The Reserve Bank created the category with the Master Direction on Non-Banking Financial Company — Account Aggregator issued in 2016, and the framework went live for customers in September 2021. There are three roles, and every paper that touches the topic asks them:
- The Financial Information Provider, or FIP, holds the customer’s data — a bank, a non-banking finance company, an insurer, a mutual fund or a pension fund.
- The Financial Information User, or FIU, wants the data to give a service, for example a lender assessing a loan application.
- The Account Aggregator itself moves the data from the FIP to the FIU on the strength of a digital consent artefact that records the purpose, the data sought and how long the consent lasts.
The defining rule is that an Account Aggregator is data-blind: it may not store, use or sell the data passing through it, and the information travels encrypted. The customer may revoke consent at any time, and an Account Aggregator may carry out no other business. The industry alliance that supports the framework is the DigiSahamati Foundation, known as Sahamati. The framework is one strand of what is called India Stack, alongside Aadhaar-based identity, e-KYC and UPI.
Digital lending and the rules around it
The Reserve Bank issued its Guidelines on Digital Lending in September 2022, acting on the report of its working group on digital lending through online platforms and mobile applications. The core rules are that all money must flow directly between the borrower’s bank account and the regulated entity’s account, with no pass-through account of a lending service provider in between; that a Key Fact Statement giving the all-inclusive annual percentage rate must be shown before the loan is signed; that there must be a cooling-off or look-up period in which the borrower may exit by repaying the principal and the proportionate cost; and that any increase in a sanctioned credit limit needs the borrower’s explicit consent. Peer-to-peer platforms are registered separately as NBFC-P2P under master directions of 2017.
Two more institutional names close the topic. The Reserve Bank’s Regulatory Sandbox, announced in 2019, lets a firm test a product on real customers in a limited way under relaxed rules, with cohorts on themes such as retail payments and cross-border payments. The Reserve Bank Innovation Hub was set up at Bengaluru in 2020 as a wholly owned subsidiary to build such products, and the Unified Lending Interface grew out of it as a common platform for lenders to draw authenticated data for credit appraisal. Card-on-file tokenisation, made compulsory in 2022, replaces a stored card number with a token so that the merchant never keeps the real number.
Exam Point of View
Banking papers ask five things here. First, the legal basis: the Finance Act 2022 amendment to Section 2 of the RBI Act, 1934. Second, the two pilot dates and their uses, 1 November 2022 for wholesale with Government securities and 1 December 2022 for retail. Third, the distinction between CBDC, UPI and cryptocurrency, usually as a statement-based question in which the trap is to call the digital rupee a payment system or to say it bears interest. Fourth, the three Account Aggregator roles, with the data-blind rule as the point to remember. Fifth, who operates which system: NPCI for UPI, IMPS, RuPay, NACH, AePS and FASTag, and the Reserve Bank for RTGS and NEFT. Keep the founding years apart: NPCI 2008, IMPS 2010, UPI 2016, e-RUPI 2021, UPI 123PAY 2022.
Important Facts
| Enabling amendment | Finance Act, 2022 amended Section 2 of the RBI Act, 1934 |
|---|---|
| RBI Concept Note on CBDC | Published October 2022 |
| Wholesale pilot, e₹-W | Began 1 November 2022; Government securities settlement |
| Retail pilot, e₹-R | Began 1 December 2022; token-based wallet |
| Interest on CBDC | None, by design |
| Distribution model | Indirect or intermediated: RBI issues, banks distribute |
| NPCI set up | 2008; not-for-profit company under the Companies Act |
| UPI launched | 2016 by NPCI |
| IMPS launched | 2010 by NPCI |
| Operated by RBI | RTGS and NEFT, both available round the clock |
| Payment systems law | Payment and Settlement Systems Act, 2007 |
| Account Aggregator direction | NBFC-Account Aggregator Master Direction, 2016; live September 2021 |
| AA roles | FIP provides data, FIU uses data, AA is the data-blind consent manager |
| AA industry alliance | DigiSahamati Foundation, called Sahamati |
| Digital lending guidelines | September 2022; direct disbursal, Key Fact Statement, cooling-off period |
| P2P lending category | NBFC-P2P, master directions of 2017 |
| RBI Innovation Hub | Set up 2020 at Bengaluru; Unified Lending Interface grew from it |
| Regulatory Sandbox | Announced by the RBI in 2019, run in themed cohorts |
Practice MCQs on this topic
Which Act was amended to widen the definition of a "bank note" so that the Reserve Bank of India could issue the Digital Rupee?
- A.Banking Regulation Act, 1949
- B.Reserve Bank of India Act, 1934
- C.Payment and Settlement Systems Act, 2007
- D.Coinage Act, 2011
Show answer
Explanation
The correct answer is B, the Reserve Bank of India Act, 1934. The Finance Act, 2022 amended Section 2 of the Reserve Bank of India Act so that the expression bank note includes a bank note issued in digital form, which gave the digital rupee the status of legal tender. Option A is wrong because the Banking Regulation Act, 1949 governs the licensing, management and supervision of banking companies and has nothing to do with the issue of currency. Option C is wrong because the Payment and Settlement Systems Act, 2007 authorises and regulates payment systems such as UPI and RTGS, but a CBDC is currency and not a payment system. Option D is wrong because the Coinage Act, 2011 deals with coins, their denominations and the Government’s power to mint them; coins are issued by the Government of India, while bank notes, now including the digital rupee, are issued by the Reserve Bank.
The pilot of the wholesale Digital Rupee, e₹-W, was launched on 1 November 2022 for which purpose?
- A.Retail payments at merchant outlets
- B.Cross-border remittances
- C.Settlement of secondary market transactions in Government securities
- D.Payment of direct benefit transfer subsidies
Show answer
Explanation
The correct answer is C, the settlement of secondary market transactions in Government securities. The wholesale pilot began on 1 November 2022 with a small group of banks, and its first use case was settling the secondary market leg of Government security trades, because that removes the need for a separate settlement guarantee arrangement and frees collateral. Option A is wrong because merchant payments belong to the retail pilot, e₹-R, which began a month later on 1 December 2022. Option B is wrong because cross-border use has been discussed as a later possibility but was not the first wholesale use case. Option D is wrong because subsidy transfers run through the direct benefit transfer system using ordinary bank accounts and the Aadhaar Payment Bridge; programmable CBDC has only been tested for such purposes, not deployed as the pilot’s first use.
Which of the following is the correct difference between the Digital Rupee and the Unified Payments Interface?
- A.Both are payment systems operated by NPCI
- B.The Digital Rupee is central bank money itself, while UPI is a system that moves bank deposit money
- C.UPI is legal tender, while the Digital Rupee is not
- D.The Digital Rupee pays interest, while UPI balances do not
Show answer
Explanation
The correct answer is B. The digital rupee is money, a liability of the Reserve Bank, so a transfer from one wallet to another is final the moment it happens and no interbank settlement follows. UPI, by contrast, is a payment instruction system run by the National Payments Corporation of India that moves money already held as a deposit in a bank account, and the banks settle between themselves afterwards. Option A is wrong because the digital rupee is issued by the Reserve Bank and is not an NPCI product at all. Option C is wrong and reverses the position: the digital rupee is legal tender under the amended Reserve Bank of India Act, while UPI is only a way of giving a payment instruction and can never be legal tender. Option D is wrong because the digital rupee deliberately pays no interest, so that savers are not drawn away from bank deposits.
In the Account Aggregator framework of the Reserve Bank of India, the entity that holds the customer’s financial data and shares it on consent is called the
- A.Financial Information User (FIU)
- B.Financial Information Provider (FIP)
- C.Consent Manager
- D.Lending Service Provider (LSP)
Show answer
Explanation
The correct answer is B, the Financial Information Provider. An FIP is the institution that already holds the customer’s data — a bank, a non-banking finance company, an insurer, a mutual fund or a pension fund — and releases it when a valid consent artefact is presented. Option A is wrong because the Financial Information User is the institution at the receiving end, which needs the data to give a service, such as a lender appraising a loan. Option C is wrong because the consent manager is the Account Aggregator itself, the data-blind pipe that may not store, use or sell what passes through it. Option D is wrong because a Lending Service Provider is an agent that sources or services loans for a regulated lender under the digital lending guidelines of 2022; it is part of the lending chain and not of the Account Aggregator framework at all.
The National Payments Corporation of India (NPCI) was set up in which year, under the Payment and Settlement Systems Act, 2007?
- A.2005
- B.2008
- C.2010
- D.2016
Show answer
Explanation
The correct answer is B, 2008. The National Payments Corporation of India was incorporated in 2008 at the initiative of the Reserve Bank of India and the Indian Banks’ Association as the umbrella organisation for retail payments in India, and it is a not-for-profit company under what is now Section 8 of the Companies Act. Option A is wrong because 2005 precedes even the Payment and Settlement Systems Act, which was passed in 2007 and is the law under which NPCI’s systems are authorised. Option C is wrong because 2010 is the year in which NPCI launched the Immediate Payment Service, IMPS, not the year it was founded. Option D is wrong because 2016 is the year in which NPCI launched the Unified Payments Interface, its best known product; candidates often give the UPI year for the NPCI year, which is the trap in this question.
Which of the following statements about the retail Digital Rupee, e₹-R, is NOT correct?
- A.It is token-based and held in a digital wallet
- B.It is issued in the same denominations as existing coins and notes
- C.It earns interest like a savings bank deposit
- D.It is distributed to the public through participating banks
Show answer
Explanation
The correct answer is C, which is the incorrect statement. The retail digital rupee earns no interest, and this is a deliberate design decision: an interest-bearing CBDC would pull money out of bank deposits and shrink the funds banks have to lend, so the Reserve Bank kept it non-interest bearing like cash. Option A is correct and therefore not the answer, because e₹-R is a token-based bearer instrument held in a wallet offered by a bank. Option B is correct because the retail digital rupee is issued in the same denominations in which coins and bank notes are now issued. Option D is correct because both pilots follow the intermediated model, in which the Reserve Bank issues the digital rupee and banks distribute it, open the wallets and handle customer service, just as they distribute cash.
e-RUPI, launched in 2021, is best described as
- A.A cryptocurrency approved by the Reserve Bank of India
- B.A prepaid, person-specific and purpose-specific electronic voucher
- C.A new denomination of the Digital Rupee
- D.A credit card product of the National Payments Corporation of India
Show answer
Explanation
The correct answer is B. e-RUPI is a prepaid electronic voucher, delivered to the beneficiary as an SMS string or a QR code, which can be redeemed only by the named person and only for the named purpose, for example a vaccination or a diagnostic test. It is cashless and contactless and needs no bank account or internet connection at the beneficiary’s end. Option A is wrong because the Reserve Bank has approved no cryptocurrency; e-RUPI is a voucher and uses no blockchain. Option C is wrong because e-RUPI is not currency at all and predates the digital rupee pilots, which began in late 2022. Option D is wrong because e-RUPI is a prepaid voucher and not a credit instrument; NPCI’s card product is RuPay, which is a separate scheme.
Under the Reserve Bank’s Guidelines on Digital Lending, 2022, the disbursal and repayment of a loan must take place
- A.Through a pass-through account of the lending service provider
- B.Directly between the borrower’s bank account and the regulated entity’s account
- C.Through a wallet maintained by the digital lending app
- D.Only in cash at a branch of the lender
Show answer
Explanation
The correct answer is B. The guidelines issued in September 2022 require that all loan money move directly between the borrower’s bank account and the bank account of the regulated entity, that is the bank or non-banking finance company doing the lending, without any pool or pass-through account of a third party in between. Option A is wrong because that is exactly what the guidelines forbid; the pass-through account was how unregulated apps had been able to divert and withhold money. Option C is wrong because a wallet of the app would again be a third-party account outside the permitted route. Option D is wrong because digital lending is by definition done without a branch visit, and the guidelines also require a Key Fact Statement with the all-inclusive annual percentage rate and a cooling-off period during which the borrower may exit by repaying the principal and the proportionate cost.
Which body operates the Real Time Gross Settlement (RTGS) and National Electronic Funds Transfer (NEFT) systems in India?
- A.National Payments Corporation of India
- B.Reserve Bank of India
- C.Securities and Exchange Board of India
- D.Indian Banks’ Association
Show answer
Explanation
The correct answer is B, the Reserve Bank of India. RTGS, which settles large-value transactions one by one in real time, and NEFT, which settles in batches, are both owned and operated by the Reserve Bank, and both have been available round the clock on all days. Option A is wrong because the National Payments Corporation of India operates the retail systems — UPI, IMPS, RuPay, NACH, AePS, the Bharat Bill Payment System and National Electronic Toll Collection — but not RTGS or NEFT. Option C is wrong because the Securities and Exchange Board of India regulates the securities market and has no role in the payment systems. Option D is wrong because the Indian Banks’ Association is an industry body of banks; it helped set up NPCI but operates no payment system itself.
The Reserve Bank Innovation Hub, set up in 2020 as a wholly owned subsidiary of the Reserve Bank of India, is located at
- A.Mumbai
- B.Bengaluru
- C.Hyderabad
- D.New Delhi
Show answer
Explanation
The correct answer is B, Bengaluru. The Reserve Bank Innovation Hub was set up in 2020 at Bengaluru as a wholly owned subsidiary of the Reserve Bank to build products that deepen financial inclusion, and the Unified Lending Interface, a common platform through which lenders can draw authenticated data for credit appraisal, grew out of its work. Option A is wrong because Mumbai is the headquarters of the Reserve Bank itself and of its Department of Payment and Settlement Systems, but not of the Innovation Hub. Option C is wrong because Hyderabad hosts the Reserve Bank’s Institute for Development and Research in Banking Technology, a different institution set up in 1996. Option D is wrong because New Delhi has a regional office of the Reserve Bank and not the Innovation Hub.
Peer-to-peer lending platforms in India are registered with the Reserve Bank of India under which category?
- A.NBFC-P2P
- B.NBFC-AA
- C.Payments Bank
- D.Small Finance Bank
Show answer
Explanation
The correct answer is A, NBFC-P2P. A peer-to-peer lending platform, which matches individual lenders with individual borrowers, must be registered as a Non-Banking Financial Company — Peer to Peer Lending Platform under master directions the Reserve Bank issued in 2017; it acts only as an intermediary and may not lend on its own book or give any guarantee of return. Option B is wrong because NBFC-AA is the Account Aggregator, a data-blind consent manager for financial information, which does no lending at all. Option C is wrong because a Payments Bank may accept deposits and offer payment services but cannot lend, and a differentiated bank licence is not a P2P registration. Option D is wrong because a Small Finance Bank is a full bank for small borrowers that both takes deposits and lends on its own balance sheet.
Frequently Asked Questions
What is the Digital Rupee or e₹?
It is the Reserve Bank of India’s Central Bank Digital Currency: the Indian rupee issued in digital form as legal tender, appearing as a liability on the Reserve Bank’s balance sheet and exchangeable one for one with cash and bank deposits.
How is the Digital Rupee different from UPI?
UPI is a payment system that moves money already held as a bank deposit, and the banks settle between themselves afterwards. The digital rupee is central bank money itself, so when it passes from one wallet to another the payment is final at once and no interbank settlement follows.
How is a CBDC different from a cryptocurrency?
A CBDC is issued by the central bank, is legal tender and always has a fixed value of one rupee. A cryptocurrency has no sovereign issuer, is not legal tender in India and has no fixed value, so it carries price risk that a CBDC does not.
When did the two Digital Rupee pilots begin?
The wholesale pilot, e₹-W, began on 1 November 2022 and was first used to settle secondary market transactions in Government securities. The retail pilot, e₹-R, began on 1 December 2022 for person-to-person and person-to-merchant payments.
What does an Account Aggregator do?
It moves a customer’s financial data from a Financial Information Provider to a Financial Information User on the strength of a digital consent artefact. It is data-blind: it may not store, use or sell the data passing through it, and the customer may revoke consent at any time.
Does the Digital Rupee earn interest?
No. The Reserve Bank kept it non-interest bearing, like cash, on purpose. If it paid interest, savers would shift money out of bank deposits into CBDC and banks would have fewer funds with which to lend.
Sources
- Concept Note on Central Bank Digital Currency — Reserve Bank of India
- Master Direction — Non-Banking Financial Company — Account Aggregator (Reserve Bank) Directions, 2016 — Reserve Bank of India
- Guidelines on Digital Lending, September 2022 — Reserve Bank of India





