The playbook offers a practical roadmap for FinTech founders who seek partnerships with banks, NBFCs, MFIs, and other FSPs in India. It covers ecosystem mapping, partnership models, regulatory readiness, founder self-assessment, value proposition development, stakeholder engagement, trust, pilots, and scale. The central message is that successful partnerships require more than strong technology. Founders must demonstrate credibility, compliance, measurable business value, adaptability, and execution discipline. Small, focused pilots and evidence-based results help build trust and support progress toward long-term partnerships.
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Who is responsible? Closing the accountability gap in financial fraud prevention
Financial fraud is a systemic problem being addressed by individual solutions. Across most markets, the response to a scam victim is to report it to the bank, file a police complaint, submit evidence to a regulator, and hope. Meanwhile, the fraud operation that targeted that victim is already processing the next call, the next transfer, and the next cash-out.
Fraud ecosystems have been deliberately engineered to move faster than the institutions designed to stop them. Banks and regulators need to move beyond better awareness campaigns or faster forms of grievance management to close this gap. It requires a fundamental redesign of accountability and understanding of who is responsible for what and when in the transaction chain.
Fraud today is professionally organized, behaviorally engineered, technically enabled, and insufficiently counter-checked in most jurisdictions. In fast-payment ecosystems, safety must be built into design, supervision, and grievance resolution systems.
The blind spots across the ecosystem
The accountability gap is not located in a single institution. Rather, it runs across the entire ecosystem, where each actor’s blind spot enables the next fraud.
Banks are positioned closest to the transaction, which should make them the most effective line of defense. Yet most fraud detection systems are calibrated to identify unauthorized transactions, such as credential theft, account takeover, and card skimming. Authorized push payment (APP) fraud is another type of fraud in a completely different category, where the victim is manipulated into initiating a payment themselves. APP bypasses most conventional controls. MSC’s Mind the Gap report found that more than 60% of fraud victims across India, Bangladesh, and Kenya did not know what grievance mechanisms existed. 48% of victims who attempted to report were dismissed for their inability to furnish evidence.
Existing grievance resolution systems are largely designed around what the institution needs and not what the victim can provide. MSC’s consumer protection research in India has consistently documented this gap across the financial services lifecycle. We have traced the cycle from transparency of product terms at onboarding, to the accessibility of recourse channels post-harm. Our customer protection in the Indian digital financial services series mapped specific failure points related to recourse and transparency that leave customers without an effective remedy when things go wrong.
In India specifically, the Prevention of Money Laundering Act (PMLA) creates a structural paralysis, as banks cannot freeze suspected mule accounts without authorization from the court or law enforcement. This creates a legally mandated delay that fraudsters systematically exploit. The IBA Working Group has proposed that banks be granted enhanced authority to place temporary holds on suspected mule accounts before formal orders arrive, which is a necessary regulatory design reform that remains pending.
Fraud is also rampant in the telecom sector. Caller ID spoofing, SIM swaps, and the leasing of backend numbers to route fraudulent calls are all examples of vulnerabilities at the telecom layer. The UK’s Ofcom interventions show that these are solvable. Regulators can impose mandatory blocking of international calls that fake domestic numbers, block invalid caller IDs, and ban leasing backend numbers used to hijack calls. Although these are technical controls with measurable impact, most jurisdictions have not implemented them.
Digital platforms, such as social media, messaging apps, and digital marketplaces, are another source of most scams. Yet, platform accountability for fraud from their infrastructure remains largely voluntary. Recorded Future’s 2024 Payment Fraud Report identified nearly 1,200 scam domains linked to fraudulent merchant accounts and nearly 11,000 e-commerce domains infected by Magecart skimmers. This is a threefold increase from 2023. Takedown times for fraudulent pages are measured in days, while scam operations are measured in hours.
MSC’s Building trust through design report adds another perspective. Deceptive interface design, which comprises manipulative consent flows, hidden fees, and guilt-tripping prompts, erodes user agency and creates conditions for external fraud to thrive. Regulatory accountability must extend to the design layer, not only to obviously illegal content.
Even where consumers know how to report, the system often fails them. MSC’s TRUST framework identifies the precise dimensions in which most grievance systems fail. Transparency suffers when consumers do not understand the terms they agreed to. Consumers lose recourse when complaint channels close, require multiple steps, or operate in a language they do not speak. They face information asymmetry at every point, which undermines their ability to understand what happened. Security investments fall behind. And once fraud occurs, timeliness matters most, yet procedural compliance systematically sacrifices it.
What effective accountability looks like
Three jurisdictions have moved furthest towards a systemic accountability model. Their approaches converge on the common principle that fraud prevention is a shared responsibility across the transaction chain, not a consumer obligation.
Since October 2024, payment service providers in the UK must reimburse APP fraud victims more than USD 100,000, with costs split between sending and receiving banks. The one-year assessment showed that reimbursement alone is insufficient, as it simply compensates victims but fails to break the criminal business model. The more impactful interventions have been at the telecom layer, such as caller ID blocks, filters for invalid numbers, and requirements for operators to verify business customers.
In Australia, the Scams Prevention Framework was passed in early 2025. It requires banks, telcos, and digital platforms to implement defined controls or bear liability for losses, with penalties of more than USD 35 million or 30% of turnover during the breach period. It includes digital platforms as designated entities and becomes the first framework to formally extend accountability to the channels where scams originate.
Singapore’s Shared Responsibility Framework, effective December 2024, allocates liability in a defined sequence. In it, liability falls first on the financial institution, then on the telecom operator, and finally on the consumer. This can occur only if both institutions have fulfilled their obligations. This waterfall model establishes clear, predictable accountability for each actor and upholds the principle that consumers should not bear losses when institutions have failed in their duties.
What behaviorally informed prevention actually requires
Accountability frameworks set the incentive structure. But institutions and regulators must make different design decisions to build the actual prevention architecture.
- Contextual friction, not generic warnings: Transaction-level interventions, such as cooling-off periods for high-risk payments, purpose prompts, and real-time behavioral flags, are demonstrably more effective than warning messages delivered at onboarding. India’s NPCI removed P2P UPI collect requests, a concrete example of friction designed into the system.
- Cross-institutional intelligence sharing: Mule account registries, cross-bank fraud signals, and real-time data sharing between banks, telcos, and platforms turn individual detection into network-level prevention. India’s MuleHunter.AI at the RBI Innovation Hub is an early example of this direction.
- SupTech and RegTech investment: MSC’s SupTech data maturity framework finds that one-third of regulators still rely on manual submissions, and fewer than 10% of smaller jurisdictions have full data standardization. The limiting factor is data quality. Many authorities validate data manually. Regulators cannot supervise what they cannot measure. Fraud cannot be detected if reporting systems lag transactions by weeks.
- Capability-building as a regulatory obligation: Financial literacy must shift from a CSR activity to a mandatory, measurable output. To address this, MSC’s PTE Framework offers a practical model for how phygital capability delivery driven by teachable moments can be designed, contextualized, and evaluated across diverse user segments.
- Victim-centered grievance design: Regulators can use the MSC TRUST framework to redesign grievance resolution systems to build solutions from the victim’s perspective. These should be accessible in local languages, multi-channel, credible, and be able to initiate protective holds without a court order.
The way forward
Fraud today is institutionally tolerated due to design fragmentation: Banks are responsible for transactions, telcos are responsible for calls, platforms are responsible for content, and regulators are responsible for their own sectors. In the space between those silos, fraud operations run freely.
The evidence from the UK, Australia, and Singapore, and from MSC’s field research across Asia, Africa, and the Pacific, proves that institutions must design protection into the transaction rather than just bolt it on. It also requires a grievance management system built for the person who has just been deceived, not for the institution that manages its liability.
The fraud supply chain is end-to-end, and the protection system that counters it must reflect this reality.
This is Blog 3 of a three-part MSC series on fraud supply chains. Blog 1 examined why ordinary people fall for fraud. Blog 2 examined how fraud operations are industrialized and monetized.
Climate-resilient affordable housing finance: From affordable at origination to affordable over time
Today’s changing climate alters what affordability means for borrowers, homes, and housing finance portfolios. Affordability can no longer be assessed solely by whether a borrower can afford the equated monthly installment (EMI) during origination. It must also account for the household’s ability to continue to occupy, maintain, repair, and repay the home over the life of the loan.
India’s affordable housing challenge is often assessed by the scale of housing demand addressed through homes sanctioned, constructed, or financed. While these metrics remain important, they do not fully capture whether a home will remain safe, livable, and affordable over the loan period. A home that appears affordable at origination may become increasingly expensive if the household faces higher cooling and water costs, climate-related health expenses, or repeated repairs after floods, cyclones, or extreme heat. Affordability should therefore cover the life of the home and the loan.
The urgency of this issue is evident. More than 80% of India’s population lives in districts at risk of climate-induced disasters. Rising temperatures, changing rainfall patterns, groundwater depletion, intense cyclones, and sea-level rise can affect homes and livelihoods. This creates a dual risk for affordable housing borrowers. A climate event can damage the financed property and disrupt the household’s income. This interaction between asset damage and livelihood interruption is vital for lenders that serve households with limited financial buffers.
The risks are particularly significant for economically weaker sections (EWS), lower-income groups (LIGs), and households with informal or variable incomes. Government housing programs provide important financial support, but they may not always fully cover construction costs. This can potentially leave beneficiaries with a residual financing requirement. Pradhan Mantri Awaas Yojana-Urban (PMAY-U), Pradhan Mantri Awaas Yojana-Gramin (PMAY-G), and various state-level housing schemes provide subsidies and other forms of assistance. These schemes create a potential role for complementary lending, including top-up and stage-based construction finance. However, secondary evidence suggests that access to such formal credit remains relatively limited for many beneficiaries. For instance, as noted in the Standing Committee on Housing and Urban Affairs’ analysis of PMAY-U, the average cost of an EWS house was estimated at approximately INR 0.65 million (USD 6,850) as of 2022. The center, the states, the urban local bodies (ULBs), and the beneficiary were expected to share the cost. While the central contribution is fixed on a per-unit basis, the contributions from the states and ULBs help keep the overall cost affordable for the beneficiary. The Committee observed that variations in the extent of state-level contributions could, in some cases, result in beneficiaries being required to make higher contributions. The average beneficiary contribution was estimated at around 60%, highlighting the potential need for additional financing. In this context, financial institutions can help bridge the residual financing gap through appropriately structured top-up and stage-based construction finance, particularly for households with limited access to conventional housing finance.
The International Finance Corporation (IFC) and Aavas Financiers’ market research on green affordable housing finance also found that 62% of loans for new housing from affordable housing finance companies fund This profile of small, self-built, incrementally expanded housing has important implications for climate resilience. Such homes often fall outside the reach of green-building certification and developer-led green mortgages, yet they are among the most exposed to extreme heat, flooding, and structural vulnerability. Resilience cannot arrive in this segment as a ready-made product. Households must build it feature by feature through stronger roofs, raised plinths, and better drainage during construction or improvement. Climate-responsive finance must therefore reach the household that adds a room, replaces an unsafe roof, or builds gradually on an owned plot.
The research suggests that the intersection of climate and affordable housing finance should extend beyond green mortgages for developer-built projects. Much of the demand involves self-construction, renovation, reconstruction, vertical expansion, and completion of houses stalled by funding gaps.
The relevant interventions need not always involve complex technology. Depending on local conditions, they may include cool roofs, improved shading and ventilation, rainwater harvesting, water-efficient fixtures, raised plinths, stronger drainage, flood-safe electrical systems, and improved roof anchoring. However, affordability remains a challenge. A National Housing Bank (NHB)- study estimated that green features increase residential construction costs by approximately 3.6%. Although these measures may lower utility and repair costs over time, the additional upfront expense can strain lower-income households.
The IFC and Aavas Financiers’ primary research in Jaipur and Indore reinforces this finding. Households in the affordable segment showed broad willingness to adopt green features, but around 60% cited higher upfront costs as the main barrier. Lower-income respondents would, on average, need the next tier of green features at roughly 30% lower cost before they would opt in. Awareness of green home loan products stood at just 7%, and most respondents said they would take one only if it offered interest-rate concessions or fee waivers.
Addressing these risks requires ain how affordability is defined from affordability based on loan amount to affordability based on design. A house is not truly affordable merely because its EMI fits the borrower’s present income. It must also remain affordable to occupy, maintain, and repair. Construction rarely relied on one source of finance. Households relied on a mix of savings, chit funds, gold, personal loans, informal borrowing, and housing finance. A climate event that reduces income or creates an unexpected repair, water, electricity, or healthcare expense can disturb this already delicate balance.
For lenders, the risk extends beyond household cash flow. A flood can damage the mortgaged property, disrupt a small business, and destroy household assets all at once. A heatwave can reduce working hours for outdoor workers while increasing cooling and healthcare expenses. The resulting chain is clear:
This distinction is relevant in a market where smaller loans are not necessarily simpler loans. India’s housing loan market stood at approximately USD 410 billion in portfolio outstanding as of FY25. It grew at around 13% annually from FY20 to FY25, with nonbanking financial companies (NBFCs) and housing finance companies (HFCs) holding roughly one-fifth of the market.
In this scenario, the affordable segment has a distinct risk profile. CRISIL estimates show that gross non-performing assets (NPAs) for affordable housing loans stand at approximately 2.6% in FY25, roughly twice the 1.2% recorded for overall housing loans. This occurred even as asset quality across retail lending improved.
This gap does not establish climate change as a cause of delinquency. It does, however, indicate that affordable-segment borrowers already operate with thinner margins for error. These borrowers are predominantly self-employed or informally salaried households that manage phased construction, mixed financing, and limited financial buffers. Climate-related shocks could intensify these underlying pressures.
The response must begin with an understanding of the local market. Affordable housing markets already differ across districts in terms of income patterns, construction practices, land documentation, housing aspirations, and repayment capacity. Climate risk introduces another layer of variation. A heat-prone district may require a different housing and finance package from a flood-exposed coastal area or a water-stressed inland market. A single national green home loan is unlikely to address these differences.
Product, underwriting, and servicing models must therefore evolve together. Construction-linked loans can include stage-based disbursement, modest top-up flexibility, and simple technical guidance. Property appraisal can consider flood history, drainage, heat exposure, water availability, and structural vulnerability alongside title, valuation, and loan-to-value ratios. The same site visits used to verify loan utilization can check whether essential resilience features are in place. Lenders can also establish predefined post-disaster protocols, including early customer communication, repair finance, and temporary repayment flexibility.
Public policy provides an entry point for this transition. Pradhan Mantri Awas Yojana-Urban (PMAY-U) 2.0 advises states and union territories to raise awareness of innovative construction technologies and materials that enhance thermal comfort, energy efficiency, disaster resilience, and cost-effectiveness. This initiative creates an opportunity to integrate simple climate-resilience checks into beneficiary-led construction, housing finance, and construction-stage monitoring.
Affordable housing finance must ultimately protect three things: the borrower’s repayment capacity, the home’s physical resilience, and the long-term quality of the lender’s portfolio. India still has an opportunity to embed climate considerations into millions of homes that are yet to be built or improved. Building climate resilience into affordable housing finance now will prove more affordable and equitable than financing homes without adequate resilience and paying for a retrofit later, after households and lenders have already absorbed the cost.
Beyond LPG access: Reimagining the future of clean cooking in India
For millions of Indian households, access to liquefied petroleum gas (LPG) is no longer the primary challenge. The bigger challenge is ensuring that households can use it regularly, reliably, and safely.
Sarita, a Pradhan Mantri Ujjwala Yojana (PMUY) beneficiary, experienced this gap firsthand. Her story, featured in the first blog in this series, reflects the everyday challenges that many households face after they gain access to LPG.
Consumers face affordability, constraints, sudden dry-outs, uncertain delivery timelines, and safety concerns. Delivery personnel encounter unpredictable demand, distributors deal with inefficient logistics, and oil marketing companies (OMCs) lack visibility into actual consumption patterns. The government also faces challenges with subsidy targeting and curbing diversion.
Although these challenges appear disconnected, they stem from a common underlying issue. India’s LPG ecosystem has expanded significantly, but its last mile remains largely invisible.
The question, therefore, is not whether India needs more LPG cylinders or more distributors, but rather, what if the missing layer in India’s LPG ecosystem is digital?
Over the past decade, India has shown how digital infrastructure can transform large-scale public systems. Aadhaar provided a trusted digital identity that enabled targeted service delivery. The Unified Payments Interface (UPI) transformed payments through real-time, interoperable transactions. More recently, smart electricity meters have improved power distribution through real-time consumption data and remote meter readings. These digital transformations have improved transparency, efficiency, and inclusion. They have also created a digital layer that enables seamless information exchange across complex ecosystems.
The same principle can apply to LPG. Digital tools and Internet of Things (IoT)-enabled sensors across the LPG value chain can provide real-time insights into distribution, payments, and usage patterns.
India has one of the world’s largest physical LPG distribution networks. Millions of cylinders move each day from bottling plants to distributors and then to households. Yet, once a cylinder reaches a household, the ecosystem has limited visibility into its use until the consumer books another refill. As a result, decision-making relies on historical refill records rather than real-time consumption patterns.
A digital layer on this physical network requires one critical building block: bringing IoT-enabled sensors to the last mile. These sensors can monitor household consumption and securely transmit real-time information to a digital platform. This system can transform a conventional cylinder into an information-driven asset. It can also provide real-time visibility across the value chain and improve information flow throughout the ecosystem. Better information can support decisions for consumers, distributors, OMCs, and policymakers.
Just as smart electricity meters allow users to monitor power consumption and pay for actual use, a smart LPG ecosystem can give households greater control over their LPG use. It can also offer more flexible payment models. A pay-as-you-go (PAYG) approach allows households to pay only for what they consume rather than pay for a full cylinder upfront. This model can address the high upfront cost of LPG cylinders.
Unlike conventional households that estimate the remaining gas by lifting or shaking the cylinder, Sarita uses a digital LPG app linked to an IoT-enabled sensor on her cylinder. The sensor tracks her real-time LPG use and sends a push notification through the app. The notification shows how many days of LPG remain. The app also alerts her when the system places a refill request. This feature reduces uncertainty and helps prevent sudden dry-outs during cooking.
For Sarita, the benefits extend beyond timely refills. Instead of making a large upfront payment for a replacement cylinder, she could pay for the LPG she consumes. This model resembles prepaid smart electricity meters. It spreads the cost across smaller, more manageable payments. Such a model could ease the financial burden on households with irregular incomes. It could also encourage more consistent LPG use.
A few days later, Sarita receives an alert about a potential gas leak in her kitchen. The IoT-enabled system can detect unusual gas flow patterns that may indicate a leak. In such cases, the regulator could automatically shut off the gas supply. This would give Sarita time to contact the distributor. An event that once relied on intuition, self-vigilance, and periodic inspection can now be supported by real-time information.
Such solutions must account for varying levels of digital literacy, technological familiarity, and access to smartphones and the internet among households. A phased approach can help the system mature, improve accessibility, and support wider adoption over time.
While Sarita’s experience is illustrative, the benefits are not limited to a single household. The same information can improve last-mile operations and enable smarter distribution. Real-time monitoring of LPG use can reduce uncertainty in everyday cooking.
Delivery planning by distributors after they receive refill orders can result in uneven workloads, suboptimal route planning, and higher logistics costs. Instead of waiting for a household to submit a refill request, the system could forecast demand based on actual consumption patterns. Better visibility could also help distributors anticipate refill requirements, schedule deliveries proactively, improve workforce deployment, minimize delays, and reduce the need for households to maintain a second cylinder as a precaution.
For OMCs, access to last-mile data could improve production planning, cylinder utilization, and inventory planning across regions. It could also minimize operational losses from diversion and inefficient asset deployment.
From a governance perspective, the advantages of a smart and data-driven LPG ecosystem extend beyond operational efficiency. For governments and policymakers, real-time visibility into household-level consumption trends could help improve subsidy targeting. It could also support a robust monitoring protocol for subsidized LPG distribution and enable evidence-based policymaking.
The transition to a smart LPG system can occur incrementally, without requiring a complete overhaul of the existing infrastructure. Smart sensors could initially be introduced through pilots in selected geographies and integrated with existing distributor and OMC networks. As the technology and operating model mature, coverage could expand across households. Data platforms, customer interfaces, and delivery systems could also be gradually integrated to enable smoother information flow. This phased approach would allow stakeholders to test the technology, refine operating processes, and build the capabilities required for scale.
Real-time data on last-mile consumption behavior could also help identify irregular use patterns that may indicate diversion of subsidized domestic cylinders for commercial use. Instead of relying mainly on periodic audits or refill histories, the government could use granular, ground-level data to monitor the system more effectively and respond proactively.
Besides better day-to-day operations and governance, digital LPG could also serve a larger strategic purpose: strengthening India’s energy resilience. Rising geopolitical tensions and volatile global energy markets make real-time demand management increasingly important for energy security.
For decades, the debate on energy security has focused on higher storage capacity. Recent geopolitical tensions have also highlighted the need to maintain adequate strategic LPG reserves. But as India’s LPG ecosystem continues to expand, another equally important question arises: Can resilience emerge from effective management of the existing system, and not from storage alone?
Digitalization can help achieve this. Rather than treating millions of household cylinders as the end of the supply chain, stakeholders can integrate them into a connected network. This network can provide insights into consumption trends, demand changes, and inventory needs. It can also help supply chains respond proactively to disruptions and use existing assets better.
This has a significant implication. India’s future energy security strategy may depend less on how much LPG it stores and delivers and more on how intelligently it manages the LPG in circulation.
A smarter LPG network can help India move from access to LPG to reliable, sustained, and informed use. Over the past decade, the country has built one of the world’s largest clean cooking networks. The next decade offers an opportunity to make this network smarter. Every refill can generate useful insight. Every cylinder can become part of a connected system. Every stakeholder can benefit from real-time information.
Reimagining rural MSME finance: How collaborative lending strengthens India’s regional rural banks
This policy explores how collaborative lending can help Regional Rural Banks (RRBs) strengthen their role in financing rural micro, small, and medium enterprises (MSMEs). It focuses on how partnerships can combine RRBs’ regional presence and customer relationships with complementary capabilities from other lending institutions. The report highlights how such collaboration can support wider and more effective access to formal finance for rural businesses, while strengthening RRBs’ capacity to diversify their portfolios and deepen their engagement with the rural MSME segment.
Co-lending in India: Tracing the evolution of a collaborative lending framework
This policy brief examines the evolution of India’s co-lending framework from a priority-sector mechanism to a standardized model for collaborative credit delivery. It traces key Reserve Bank of India (RBI) milestones from the 2018 co-origination guidelines and 2020 co-lending model to the 2025 Directions. The brief examines changes in eligibility, risk-sharing, governance, customer protection, and operational processes. It highlights how the framework can expand credit access for underserved borrowers while balancing innovation with prudential oversight.
