Thread by @iam_anandv

Time to do a @ZetaIndia thread, because it is a text book case of not getting caught out in the public domain. Let us begin.

1. First the @RBI notifications. It is true that they had put a Master KYC document that mandated Aadhaar.
Link: rbi.org.in/ScriptS/BS_Vie…

2. There is a glorious S-15 regarding Identity information mandating Aadhaar biometric OTP, but however a subsequent Gazette notification kept it at abeyance.

Link: egazette.nic.in/WriteReadData/…

(Our context is still existing accounts)

3. So RBI put out a circular and kept that in abeyance because SC said so. Now we come back to PPIs. Now @Logic says, they are governed by different set of regulations, but are still governed by PMLA. Since PMLA is kept on abeyance, we need to look at PPI regulations.

4. The PPI regulations put out by @RBI is here:
Link: rbi.org.in/scripts/BS_Vie…

They need to be compliant to master KYC instructions time to time. But however that is still under suspension.

5. Now what about Meal cards? It is covered by the same PPI guidelines. So we are still on "Suspicious territory" on Zeta asking for Aadhaar.

Now let us go further.

6. For a Meal card that only has 10K/month transactions, a normal KYC is good enough, for one year. After that they have to convert to Full KYC as per the regulations. So @gramki is accurate on that point.

7. Is Full KYC only Aadhaar? yes, As per Master circular. But there PPI is on the same footing like Bank accounts. The gazette explicitly does not mention PPIs, but surely what works for Bank a/cs should work for PPIs right? Here is where it gets even more fun.

8. PPIs lost access (e.g.) Fino, PayTM and are supposed to move to VID based authentication only. They are supposed to have Aadhaar vault, DB in HSM and apps must use hashed id etc. etc. This of course is a pain for wallets. So they simply ask for any ID # and keep running.

9. When we come back to biometric auth, can any random agent of the bank do it? Nope. This must be done only in the presence of a bank official. And does Zeta send a bank official? 😀.

10. Now all this pales in comparison with the Super card, which is even more fun.

11. From link: zeta.in/press-releases…

I hope this is not how things are today, because it is definitely not how it should be.

12. So how should things actually work on KYC? By using the KYC API of course. But that is not the claim that was made. Notice carefully the Yes/No claim. It is not even the limited KYC API claim.

https://twitter.com/gramki/status/1037733761452916736

13. So Zeta is a technology partner, needs to do KYC, but does only Yes/No? That is because Sub-KUAs are not allowed. What about Sub-AUAs? But can any Sub-AUAs go via Banks? What are you saying @UIDAI? Allowed, not allowed? OK? Not Ok?

14. This brings back the question, What is a technology partner? Not AUA, Not KUA, Not Sub-AUA, just someone who has API access? I will love to hear some answers.

@Logic add your Qs here because you track PPI better than me.

15. @Logic found one other thing. What exactly is this?
Link: docs.zetaapps.in/display/OND/Ge…

@Nixxin as per @ZetaIndia, Full KYC is allowed via other IDs, just not Aadhaar KYC. So why are they not giving it as an option?

16. This is Epic! They are doing eKYC and explicitly say so. It is not a bank, but a bank partner. It is not getting eKYC response, but it is getting Yes/No. But consent is for eKYC and for getting Aadhaar details.

Now we are getting somewhere...