Consent Architecture in Financial Services Distribution: Comparing RBI’s Responsible Business Conduct Directions and the DPDP Framework

The Reserve Bank of India (RBI) issued the Responsible Business Conduct (Second Amendment) Directions, 2026 on 15 June 2026, materially revising the framework for distribution of financial products with heavy emphasis on consent architecture. Consent is now expected to be a distribution control and accountability mechanism for regulated entities. For fintechs, banks, NBFCs, loan service providers, digital marketplaces and embedded finance platforms, the key issue is how this architecture interacts with the Digital Personal Data Protection Act, 2023 (DPDP Act) and the DPDP Rules, 2025, particularly given the RBI directions take effect on 1 January 2027 and the DPDP framework becomes operational from 13 May 2027.

30 June 2026