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Dvara Analysis Weblog | Designing efficient consent artefacts beneath the Account Aggregator framework

Beni Chugh
Dvara Analysis
Srikara Prasad
Dvara Analysis

The authors thank Anubhutie Singh for her editorial overview of the piece.

Knowledge safety is gaining salience in digital monetary providers. Consent is a vital, needed (even when not ample) ingredient of any knowledge safety toolkit. The Reserve Bank of India through its guidelines for digital lenders and the Digital Personal Data Protection Bill 2022, each emphasise the necessity for efficient consent artefacts.

But, there may be a lot left to be desired within the design of consent artefacts. A number of research present consent artefacts are crafted as dense, prolonged authorized notices in English—dissuading prospects from studying it. Even when prospects overcome their psychological biases to devour them, they don’t comprehend them given their kind. They’re unable to recall what they consent to or think about its implications. That is in stark distinction with the regulatory imaginative and prescient of creating prospects aware of using their knowledge and giving them the knowledge and company wanted to successfully take into account their consenting resolution.

Dvara Analysis and Final Mile are collaborating on a behavioural science knowledgeable main examine to unpack the obstacles that prospects at the moment face in partaking with and understanding consent artefacts. This understanding is used to tell the design of consent artefacts supplied in digital monetary providers. As the primary case-study on this collection, we apply these findings to tweak the consent artefacts supplied by account aggregators within the case of digital lending. This blogpost introduces the examine.

A. Introduction

The newly launched Findex Knowledge signifies that a big hole nonetheless exists in how totally different prospects use formal monetary providers.[i] Solely about 19% of adults in India lean on formal loans whereas casual lending from social community stays fairly excessive.[ii] Estimates counsel that there exists a credit score hole of about 330 bn USD in India.[iii] Wanting beneath the hood, the widespread suspects—regional and gender gaps additional skew the entry to monetary providers, together with however not restricted to credit score. Per non-public estimates, northern and japanese elements of India lag in digital transactions.[iv] Equally, Findex Knowledge suggests that girls lag males in cellular possession by 20%, impeding their entry to digital monetary providers.

To additional inclusion, suppliers have to reimagine product choices and interfaces. They must recast the supply chains and reinvent their vocabulary, buyer expertise and safeguards. New-to-finance prospects are at a higher threat of monetary frauds resulting from their reliance on brokers and different go-betweens for help. Buyer journeys of merchandise should account for his or her distinctive wants and vulnerabilities.

On this context, the Account Aggregators (AAs) who have been created to bridge the hole between prospects and monetary providers by facilitating info movement throughout the monetary ecosystem, assume an vital function. AAs might assist prospects – particularly these with little to no formal monetary historical past – entry a greater high quality of monetary providers by serving to monetary service suppliers higher perceive a buyer’s monetary profile.[v]

However the design of the AA consent artefacts might make their use difficult for patrons.

B. Challenges with consent artefacts within the AA framework

Specific, knowledgeable, and revocable consent is the spine of the AA framework. There may be ample literature to ascertain that the majority prospects don’t learn or comprehend consent artefacts earlier than consenting. Successfully, the knowledge asymmetries that outline the relation between the supplier and the client, stay intact, regardless of the consent artefact.[vi] Even when prospects comprehend the consent artefact, they might endure from bounded rationality and should not have the ability to utterly recognize the phrases and situations of information sharing which will affect them to take a sub-optimal resolution. These considerations apply to each savvy and non-savvy prospects however could also be notably accentuated for the latter.[vii]

Our main analysis signifies that unsavvy prospects typically discover digital ecosystems overwhelming, discover themselves ill-equipped to understand and replicate on phrases and situations to make knowledgeable choices.[viii] This may typically breed distrust and worry of formal finance.

Given AA’s goal of monetary inclusion, their interface and design must be reimagined for new-to-finance, much less literate, digital immigrant, low-income prospects. There’s a have to make consent artefacts extra inclusive, to raised serve new-to-finance, much less literate, digital immigrant, low-income buyer.

C. The examine: Designing inclusive consent artefacts

  1. Goal: The target of the examine is to design inclusive consent artefacts for the AA framework. This may allow AAs to raised serve all prospects together with those that are new to know-how and DFS, and who’ve restricted common, digital, and monetary literacy. These artefacts could be designed for each smartphone and have cellphone customers.
  2. Characterising inclusive consent artefacts

    : Constructing on the authorized and regulatory necessities positioned on consent, by the RBI and the proposed DPDP as nicely the obstacles that customers face in partaking with consent artefacts, the examine proposes an inclusive consent artefact would fulfill six components:

    • Accessible,i.e., conspicuously accessible and designed for each characteristic and sensible telephones.
    • Understandable, i.e., straightforward to grasp.
    • Free, i.e., consent shouldn’t be coercive.
    • Knowledgeable, i.e., it ought to set out all needed info and require an affirmative motion.
    • Particular, i.e., it ought to point out the granular functions of processing for which consent is being taken.
    • Revocable, i.e., able to being withdrawn.

Options (iii) by way of (vi) construct on the RBI Master Directions for Account Aggregators and the RBI Guidelines on Digital Lending. Options (i) and (ii) are preconditions wanted for the consent artefact to successfully fulfill the opposite options.

  1. Research Design:

    The examine builds on a main examine designed to attract out the challenges that customers face in partaking with consent artefacts. That is finished by way of a behavioural recreation which simulates a number of real-life contexts wherein customers would possibly work together with AA-based consent artefacts and the friction and obstacles they expertise in meaningfully interact with it.

These findings are synthesised to extract design levers that might assist individuals overcome these obstacles. These design levers additional inform the creation of a toolkit of particular design options, whose presence would improve customers’ engagement with and comprehension of the consent artefact.

All materials generated beneath the examine will likely be publicly accessible, accessible by way of this page.


[i] Demirguc-Kunt, A., Klapper, L, Singer, D., and Ansar, S., The International Findex Database 2021: Monetary Inclusion, Digital Funds, and Resilience within the Age of COVID-19,WORLD BANK, July 2022, retrieved from


[ii] Demirguc-Kunt, A., Klapper, L, Singer, D., and Ansar, S., The Global Findex Database 2021: Financial Inclusion, Digital Payments, and Resilience in the Age of COVID-19,WORLD BANK, July 2022, retrieved from

[iii] OCEN & Account Aggregators will change digital lending in India, Sahamati,04 August 2020,

[iv] Boston Consulting Group, PhonePe, Digital Funds in India: A US$10 Trillion Alternative, PHONEPE,2022,

[v] Kemp, Ok., Dvara Analysis, Large Knowledge, Monetary Inclusion and Privateness for the Poor, 22 August 2017,; Le Hourou, P. & Schulman, D., World Financial Discussion board, Expertise is delivering higher entry to monetary providers. Right here’s how, 20 April 2018,

[vi] Aiyer, M. & Chugh, B., Dvara Analysis, Designing a consent artefact for digital monetary providers to cater to constrained customers, November 2021,

[vii] Aiyer, M. & Chugh, B., Dvara Analysis, Designing a consent artefact for digital monetary providers to cater to constrained customers, November 2021,

[viii] Dvara Analysis, CGAP, and Dalberg, Privateness on the Line: What do Indians take into consideration privateness & knowledge safety?, DVARA RESEARCH, 16 November 2017,

Cite this weblog:


Beni Chugh, S. P. (2022). Designing efficient consent artefacts beneath the Account Aggregator framework. Retrieved from Dvara Analysis.


Beni Chugh, Srikara Prasad. “Designing efficient consent artefacts beneath the Account Aggregator framework.” 2022. Dvara Analysis.


Beni Chugh, Srikara Prasad. 2022. “Designing efficient consent artefacts beneath the Account Aggregator framework.” Dvara Analysis.

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