Layer 3 · rule-buyers · the sousveillance stack
Who buys the rules of Indian finance?
Regulators write the rules; RegTrac watches the writers. SROs borrow them; SROTrac watches the borrowers. This register watches the buyers: the interests that flood consultations, get the meetings, and hire the regulators after retirement. Access and influence are documented through published comments, RTI replies, minutes and appointment orders — not vibes.
watching the watchers, room threeComment-transparency scorecard
The first test of a captured consultation is whether anyone can see what was said to the rule-writer. Stance per desk, as verified on the regulator's own site.
| Desk | Statute | Publishes comments? | Documented practice | |
|---|---|---|---|---|
| Insolvency and Bankruptcy Board of India | Insolvency and Bankruptcy Code 2016 | yes | Runs a Public Comments section; its discussion papers instruct commenters to submit through the website with stakeholder categories, and comments are published there. | source |
| International Financial Services Centres Authority | IFSCA Act 2019 | unknown | Consultation papers listed on ifsca.gov.in. Whether comments received are published is unverified — flagged for checking. | source |
| Insurance Regulatory and Development Authority of India | IRDA Act 1999 | unknown | Consultation papers published on its portal. In June 2026 IRDAI proposed a formal regulation-making framework: minimum 21-day public comment window and a general statement of response to comments published by the date regulations are notified. Until notified, publication of comments is not a settled practice. | source |
| Pension Fund Regulatory and Development Authority | PFRDA Act 2013 | unknown | Consultation papers published on the site (e.g. Sept 2025 valuation-alignment paper via PIB). Whether comments received are published is unverified — flagged for checking. | source |
| Reserve Bank of India | Reserve Bank of India Act 1934 | no | No general practice of publishing comments received on discussion papers. Commenters self-publish instead (NASSCOM posted its own submission on the Charges paper; Vidhi posted its 2019 PA/PG submission). Individual comment-archives exist only because commenters chose to publish. RTI is the fallback route. | source |
| Securities and Exchange Board of India | SEBI Act 1992 | yes | Posts consultation papers and the comments received on its public-comments portal; a board-approved procedure (18 Dec 2024) formalised pre-legislative consultation for regulation-making. | source |
Why the person paying should care: when comments are secret, you cannot tell whether a rule was rewritten for the industry that asked — or tested against the public that pays. RBI's 2022 Charges-in-Payment-Systems paper drew submissions from every major industry body; none were published, and the commenters had to self-publish. A rule made in a closed room still lands on your bill.
Live consultations
- 2026-10-25Public Consultation Paper on Recalibrating Economics of Insurance Distribution (commissions, EoM, Bima Sugam, Public Insurance Registry)IRDAI
- Consultation Paper on Review of Closing Auction Session, Market Timings and Settlement Methodologies for Derivative ContractsSEBI
The full consultation ledger →
The revolving door, on the record
- 2026-09-16N.S. Vishwanathan → Finance Industry Development Council (FIDC — NBFC SRO)Reserve Bank of India
- 2026-07-05Debasish Panda → Bandhan Bank LtdInsurance Regulatory and Development Authority of India
- 2026-06-01Ashwani Bhatia → ICICI Bank LtdSecurities and Exchange Board of India
- 2026-02-25Ajay Tyagi → PRISM (Oravel Stays Ltd, Oyo parent)Securities and Exchange Board of India
- 2026-01-29G. Mahalingam (Gurumoorthy Mahalingam) → Life Insurance Corporation of IndiaSecurities and Exchange Board of India
- 2025-12-19B.P. Kanungo → IIFL Finance LtdReserve Bank of India