1. INTRODUCTION
On October 16, 2018, the Reserve Bank of India (the
"RBI") issued guidelines (the
"Guidelines") for the interoperability
of know-your-customer ("KYC") compliant
prepaid payment instruments
("PPIs")1. These Guidelines
were widely anticipated ever since the RBI had issued the Master
Directions on Issuance and Operations of Prepaid Payment
Instruments2 (the "Master Direction on
PPIs") in 2017, which, among others, had introduced
interoperability among payment instruments such as wallets
with other wallets and bank accounts.
Interoperability essentially means the technical
compatibility that enables a payment system to be used in
conjunction with other payment systems. In the context of wallets,
it refers to the ability of individuals holding a wallet issued by
a particular issuer to undertake peer-to-peer payment transactions
with individuals holding a wallet issued by a different issuer.
