The RBI already has everything it needs for the purpose. It has a standalone control test; policy authority sitting with DPIIT; and administrative authority over the rules. All it needs is for one specific lacuna to be filled, namely, who takes charge in case of conflicting or inconsistent sector-specific interpretations of the control tests.

The PPO framework has been extensively discussed by practitioners and scholars, attracting criticism ranging from inadequate opportunity to be heard, to enforcement problems arising from the provisional nature of these orders.

This post argues that PROGA classified the game but not the money held through it. By deleting draft Rule 24, the Rules left users with a restitutionary right but no clear means of receiving payment.