Recommendation to Issue Guidelines Detailing Technical Parameters for Seamless Integration of Compliance Monitoring Systems with the DAKSH Portal

Recommendation to Issue Guidelines Detailing Technical Parameters for Seamless Integration of Compliance Monitoring Systems with the DAKSH Portal

1. Aparajitha Corporate Services Private Limited, a company engaged in providing compliance services, through the use of technology to over 2000+ clients, offers knowledge-driven, tech-enabled Financial, Corporate & Commercial along with Labour, Industrial, and Environment Health & Safety Compliance Solutions across India. Our domain-specific services are crafted to assist businesses with the necessary licenses, registrations, returns, remittances and compliance management under various domains.
2. As India’s digital ecosystem continues to expand into regulatory compliance, regulatory frameworks are becoming more dynamic, requiring proactive and technology-driven compliance solutions. Compliance partners play a crucial role in helping businesses navigate complex regulations and ensuring compliance to various legal requirements. At Aparajitha, we recognize that staying ahead in this industry requires a deep understanding of emerging technologies. As a tech-driven regulatory compliance partner, we are committed to providing innovative, adaptive, and efficient solutions that enhance and ensure compliance.
3. In this context, we appreciate the Reserve Bank of India’s (“RBI”) efforts in establishing DAKSH as a supervisory monitoring system, aimed at integrating the compliance monitoring systems of all Regulated Entities (“REs”) under a unified portal. However, no guidelines or Standard Operating Procedures (“SOP”) have been issued by the RBI for the seamless integration of these compliance monitoring systems with the DAKSH Portal. Providing clear guidelines or SOPs for integration would be highly beneficial in ensuring compliance by REs. As a dominant player in tech-driven compliance, Aparajitha will make all necessary efforts to ensure that digital compliance solutions works in a way that enhances ease of doing businesses while maintaining regulatory compliance by REs.
4. Therefore, through this letter, we wish to recommend that, the RBI issue comprehensive guidelines or a SOP to facilitate the seamless integration of the compliance monitoring systems of REs with the DAKSH Portal.
5. The DAKSH Portal is a Sup-Tech initiative launched by the RBI as an advanced supervisory monitoring system. It is a web-based, end-to-end workflow application designed to enhance the monitoring of compliance requirements and foster a stronger compliance culture among Supervised Entities (“SEs”), such as Banks, NBFCs, and other financial institutions. The application enables seamless communication, inspection planning and execution, cyber incident reporting and analysis, and provides access to various MIS reports, all through a secure, anytime-anywhere platform.
6. The Reserve Bank of India (RBI), through its circular dated 31^st January, 2024 (RBI/2023-24/117 DoS.CO.CSITEG.SEC.No.9/31-01-015/2023-24), has emphasized the need for comprehensive, integrated, enterprise-wide, and workflow-based solutions or tools to enhance the effectiveness of internal regulatory compliance monitoring. RBI has stressed that such a compliance monitoring solution/tool (“System“) should facilitate efficient communication and collaboration among stakeholders while incorporating processes for identifying, assessing, monitoring, and managing compliance requirements. In furtherance of this, RBI has advised Regulated Entities (REs) to conduct a thorough review of their existing compliance tracking and monitoring processes and to implement the necessary changes to their current Systems or adopt new Systems by 30^th June, 2024.
7. One of our Clients, who has a registered email ID on the Daksh Portal, received an RBI Circular (DoS.CO.CSITEG. No.S6185/31-01-097/2024-25) dated 25^th November, 2024. In this circular, RBI has conveyed that all Regulated Entities (REs) are required to ensure that their Systems are equipped with the necessary capabilities to seamlessly integrate with the DAKSH portal via Straight-Through Processing (“STP”) while maintaining robust data security and data protection measures. The circular further recommends that REs may use the model framework prepared by the Indian Bank’s Association (“IBA”) as a guide for implementing their Systems.
8. Although the deadline for developing a compliance monitoring system has been extended from 30^th June, 2024, to 30^th April, 2025 through the circular dated 25^th November, 2024, this extension will not serve its purpose unless REs are given clear and accurate guidance on the technical requirements for integrating their Systems with the DAKSH Portal via Straight-Through Processing (STP).
9. Upon reviewing the IBA model framework, it can be understood that the framework elaborates the desired standards for streamlining internal compliance monitoring function through a System. The parameters outlined in the framework only deal with the workflow to be incorporated into the System, such as methods for compliance assessment, compliance coverage, step-by-step process for determining compliance, senior management dashboard  etc. However, neither the circulars nor the IBA model framework address the technical parameters a System must possess in order to seamlessly integrate with the DAKSH Portal through STP.
10. The IBA’s model framework mentions that presentations were arranged with industry experts, including Price Waterhouse Coopers (PwC), Deloitte, Alpha Plus Technologies, Ernst & Young (E&Y), and Grant Thornton (GT), to gather inputs.
11. We, Aparajitha, a technology-driven compliance partner serving over 2,000 clients, constantly strive to enhance ease of doing business by digitizing compliance processes. We frequently provide recommendations to various ministries and departments, such as the DPIIT (Department for Promotion of Industry and Internal Trade), many of which have been acknowledged and implemented. It would be greatly beneficial, and in the interest of ease of doing business, for Aparajitha to be included in communications regarding the DAKSH Portal. This inclusion is particularly crucial as the integration deadline of April 30, 2025, approaches, and our clients remain unaware of the requirements to develop their Systems for seamless integration. Engaging Aparajitha in these discussions would enable us to better advise our clients on creating efficient Systems that meet RBI’s requirements and integrate effectively with the DAKSH Portal.
12. In light of the above, we wish to recommend the following:

• RBI is recommended to issue Guidelines/ Standard Operating Procedures (SOPs) that detail the technical parameters to be followed for seamless integration with the DAKSH Portal via Straight-Through Processing (STP).
• RBI is recommended to consider communicating with Aparajitha and obtaining our inputs regarding any updates or relevant information concerning the integration of Compliance Monitoring Systems with the DAKSH Portal.

K Varadan 

Chief Consulting Officer