14 Sep 2026

SROTrac Weekly #2: Register completes at nine SROs; FIMMDA stands up discipline

SROTrac Weekly #2

Week to 14 September 2026

TL;DR

The register is now complete: SROTrac tracks all nine RBI-recognised SROs, with 642 members across the seven rosters that are actually published. Additions this week: FIMMDA (financial markets) and Sahamati (account aggregators).
FIMMDA constituted a Disciplinary Committee of the Board on 1 September — its first visible enforcement machinery since RBI recognition in May 2025.
At Global Fintech Fest, RBI Governor Sanjay Malhotra warned fintechs against "structuring business around gaps between regulatory categories, scaling first and seeking clarity later" — exactly the conduct SRO codes are supposed to catch first.

Roster & register changes

Two additions took the register from seven SROs to the full set of nine.

FIMMDA joins as SRO #9. The Fixed Income Money Market and Derivatives Association of India was RBI's first SRO in the financial markets — recognised 7 May 2025 under the August 2024 framework for such SROs (Press Release 2025-2026/274). Its only public roster is a PDF dated 8 May 2025, listing 116 institutions: 12 public sector banks, 21 private banks, 34 foreign banks, 7 primary dealers, 5 financial institutions, 20 insurers, 11 small finance banks, 3 payments banks, CCIL and 2 infrastructure financiers. One watch item we've flagged on its work page: FIMMDA's own site overview still claims to be "115 member strong" with category counts that don't match the PDF. We treat the PDF as the primary source and re-check on refresh.

Sahamati joins as SRO #8. Recognised 5 June 2026 as the SRO for the Account Aggregator ecosystem — the consent plumbing that lets you share bank statements with a lender or advisor without handing over credentials. Sahamati publishes a live register of 110 Account Aggregator and related regulated entities, which we now track.

Elsewhere in the rosters: UFF holds steady at 121 members, and its homepage was updated on 12 September to lead with "RBI-recognized Self-Regulatory Organization" — recognition is now the first thing the site says about itself. FACE (85), MFIN (84), FEDAI (108) and SRPA (18) are unchanged this week. FIDC and Sa-Dhan still publish no member roster at all — two of nine SROs, and between them most of India's NBFC and microfinance lending, remain unverifiable by any consumer trying to check whether their lender answers to a code of conduct.

We also merged the members and overlap views into a single page with entity-type filters: 71 organisations sit in more than one SRO, and bank treasuries dominate the FIMMDA–FEDAI overlap.

Regulatory & consultation watch

The week's policy backdrop was Global Fintech Fest (9–11 September, Mumbai). Governor Malhotra's keynote on 10 September announced UFF's recognition (covered last week) alongside UPI Tap & Pay, an AI-powered MyUPI, and a framework for corporate bond tokenisation — that last one lands squarely in FIMMDA's fixed-income domain, making it the one SRO with a direct stake in how tokenised bond market plumbing gets standardised.

The sharper line was aimed at regulatory arbitrage: Malhotra cautioned fintechs against a mindset of structuring business around gaps between regulatory categories — scale first, seek clarity later. He also corrected the record on RBI's AI work: the model risk management document is guidance, not regulation, with a fuller AI governance framework for the financial sector still to come.

FIMMDA, meanwhile, quietly built the thing most SROs don't show you: a Disciplinary Committee of the Board, constituted 1 September under Article 34 of its Articles (circular FIMCIR/2026-27/20), chaired by independent director Manoj Rane, with Abhijit Basak (Union Bank) and Manish Luharuka (ICICI Bank). It's the first post-recognition enforcement machinery visible on its site. Note the composition: two of three members are employed by member banks. Independence from dominant firms is precisely the test the SRO model sets for itself — the Governor's own GFF framing was that an SRO's credibility depends on broad membership, independence from dominant firms, transparent standards and meaningful action against non-compliance.

What it means for consumers

Your bank's treasury desk now has a watchdog with a committee. FIMMDA's members price your forex card rates, corporate borrowing benchmarks and money-market instruments. Retail consumers never see this SRO work directly — but its standards flow into every rate you're quoted. A disciplinary committee is the right machinery; the test is whether it ever publishes an outcome.
Consent data gets an SRO. If you've shared financial data through an account aggregator, the ecosystem's 110 regulated entities now sit under Sahamati's code of conduct. That's a better escalation path than a lone complaint to a fintech app.
You still can't check most NBFC/MFI lenders. FIDC and Sa-Dhan publish no rosters. Nine SROs tracked, but consumer-verifiable accountability still covers only the seven that publish.
The gap warning cuts both ways. If a lender or payments app's business model depends on sitting between regulatory categories, its SRO membership is the first place standards should be enforced — before RBI has to act. Watch whether UFF's first code-of-conduct document names the gap-hopping practices the Governor described.

Sources

SROTrac is an independent CashlessConsumer project. Data: members, timeline, activity log. Corrections welcome.