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Anupam Sonal, former Chief General Manager at the Reserve Bank of India, is currently Senior Advisor (Regulation, FinTech & Compliance) to Scheduled Commercial Banks.
October 30, 2025 at 8:02 AM IST
Once considered a niche innovation, Artificial Intelligence has become the driving force behind progress across industries, shaping what people see, buy, borrow, and even believe. In this algorithm-driven world, effective AI governance must learn to think like the very systems it aims to oversee.
Two recent milestones, the RBI Framework for Responsible and Ethical Enablement of AI (FREE-AI) and the Competition Commission of India’s proposed framework for AI oversight in markets, mark a significant evolution in India’s regulatory approach. While one focuses on ensuring financial prudence, the other aims to protect market competition. Together, they establish the groundwork for a responsible AI ecosystem in the country.
The RBI FREE-AI recognises that financial institutions increasingly depend on learning models for core functions, including credit evaluation, trading, payments, fraud detection and risk control. Yet, when left unrestrained, such systems can magnify bias and destabilise trust. The framework, anchored in principles of explainability, data integrity, and human oversight, seeks to embed ethics directly into financial algorithms, thereby ensuring that automation serves prudence, not crisis.
In parallel, the CCI initiative reframes competition for the digital age, where market power stems not from ownership or control of assets and resources but from depth of data and predictive dominance. Algorithms can unintentionally imitate collusion, privilege affiliated entities, and even distort pricing through opaque interdependence.
CCI’s approach aims to deter such AI-induced distortions, promote algorithmic transparency, and prevent data-driven monopolies. The two frameworks, though developed for different domains, converge on shared ideals, i.e., fair and trustworthy intelligence. They affirm that just as oversight without innovation breeds stagnation, innovation without oversight and ethics will cause instability.
The Road Ahead
As AI weaves connections across sectors, its influence becomes systemic and self-reinforcing. For example, telecom data shaping credit models, health records guiding insurance plans, and trading engines reading and reacting to global sentiment. AI oversights therefore, obligated to evolve from static checks to cognitive governance: a living, adaptive discipline that audits not just outcomes but also how models behave, retrain, recalibrate, and reshape their own logic. Regulation in this new environment must be iterative, anticipatory, and as intelligent as the systems it seeks to guide. Several complementary mechanisms can make this possible.
A coherent and future-ready AI governance model for India must rest on shared oversight, synchronized regulation, strong cybersecurity, and human intelligence at the core. The first step could be establishing a National AI Audit Registry, that would act as a real-time monitoring network, flagging bias, drift, cyber vulnerabilities, and ethical anomalies through common audit templates and explainability tools. By linking regulatory outcomes across institutions, it would provide an early warning mechanism against systemic or security risks before they spread.
To anchor collaboration, a National Financial AI Regulatory Coordination Council could be created under the Financial Stability and Development Council or as a standalone body. It would spawn across regulators such as RBI, CCI, SEBI, IRDAI, PFRDA, and TRAI, ensuring consistent supervision, harmonised data standards, and a shared vocabulary for algorithmic accountability. Over time, the council could align with the India AI Mission and the proposed National Artificial Intelligence Technology Regulatory Authority Bill, 2024, connecting statutory oversight, national AI strategy, and practical governance.
Innovation and responsibility can coexist through a Public Algorithm Sandbox, where regulators, developers, and researchers test AI models on anonymized datasets under ethical and cybersecurity supervision. A National AI Ombudsman would give citizens the right to challenge algorithmic outcomes, turning accountability from a procedural formality into a public right.
Mandatory ‘Algorithmic Impact Assessments’, akin to environmental audits, could quantify AI’s broader social footprint: who benefits, who is excluded, and what systemic effects arise. The principle of “Algorithmic Reciprocity” could further require institutions to disclose their ethical standards and testing practices, fostering openness and peer accountability.
India could also pioneer an AI-RegTech Grid, a network that embeds real-time compliance APIs within AI models, allowing them to self-report bias, drift, or cyber incidents to regulators. A parallel Data Commons, governed transparently, could democratize access to anonymized datasets, curbing data monopolies and encouraging equitable innovation.
At the center of this ecosystem must stand capable humans. A School of Algorithmic Governance, jointly guided by the RBI, SEBI, and MeitY, could build a new generation of professional regulators fluent in data science, computation, ethics, and cybersecurity, able to interpret both the logic of code and its implications for safety and stability.
The INDIAai platform, developed by MeitY, NeGD, and NASSCOM, can serve as the digital backbone of India’s AI governance ecosystem by acting as a unified hub for knowledge, coordination, and accountability. It can integrate research, regulatory intelligence, and ethical standards into one accessible framework, hosting audit registries, bias-testing tools, and explainability benchmarks that regulators, developers, and financial institutions can jointly rely on. Beyond oversight, it can enable real-time monitoring of AI systems, facilitate cross-sector learning, to transform oversight into a living, adaptive process.
This model may build on India’s strong digital foundations, encompassing the India AI Mission, the National Strategy for AI (NSAI), AIRAWAT compute cloud, and India Stack (Aadhaar, UPI, ONDC, Account Aggregators), all enabling ethical, consent-based innovation. Complementary frameworks like DEPA and the National Data Governance Framework Policy (NDGFP) may protect data as a public trust, while programs such as Responsible AI for Youth, AI for All, and Digital India FutureLABs will prepare AI-aware professionals who strengthen both governance and cyber resilience. Together, these measures outline a distinctly Indian model of AI governance.
It envisions a Conscious Intelligence Society, where technology advances public good coalesced in democratic trust and not merely a digital economy ruled by algorithms. The goal is to civilise AI and ensure that innovation serves humanity with safety, equity, and moral clarity.
Global Lessons
India’s multi-regulator model of AI governance resonates with global efforts yet holds the potential to surpass them in inclusivity and adaptability. The EU’s AI Act (2024) offers a valuable precedent with its risk-based regulation and conformity checks, whose proportional approach India can emulate while avoiding the rigidity of over-centralisation. The pro-innovation, principles-based AI framework in UK (2023 White Paper) which delegates the interpretation and application of five cross-cutting principles of safety, transparency, fairness, accountability, contestability to sectoral regulators, aligns naturally with the India’s stated AI governance agenda as well as the foregoing suggestion of coordinated regulatory oversight council in India.
Further, India can draw inspiration from Singapore’s practical governance toolkits for AI (2019/2023) to create accessible frameworks for MSMEs, while the U.S. Federal Reserve and Consumer Financial Protection Bureau provide explainable, consumer-centric AI parallels to RBI’s FREE-AI the ethos.
Building on these lessons, India is uniquely positioned to lead a Global South partnership by proposing G20 ‘Ethical Intelligence Compact’, a collaborative platform for sharing AI sandboxes, audit methodologies, and governance standards. Such an initiative would not only anchor India’s global leadership in responsible innovation but also redefine AI diplomacy as a force for justice, trust, and shared prosperity.
Benefits and Trade-offs
India’s AI ecosystem is expanding at a breathtaking speed, demanding governance that evolves as dynamically as the technology itself. Oversight can no longer rely on static norms; it must function as a living system which is adaptive, anticipatory, and ethically grounded. The framework outlined earlier can extend beyond finance and markets to healthcare, education, logistics, manufacturing and so on.
Though each domain applies AI differently, the core imperatives remain the same: data integrity, fairness, cybersecurity, and transparency. As such a well-defined, overarching framework with minimum standards and practices, fortified with appropriate security measures will provide surety, consistency and confidence in adherence to the rules and guide a fair, transparent and ethical application of AI across the spectrum.
Such a unified governance architecture built on common core principles, strong safeguards , and shared accountability would ensure consistency without curbing innovation. It would prevent duplication of efforts across sectors, lower compliance costs, and shorten the learning curve for new entrants. AI sandboxes could act as collaborative proving grounds, thus allowing regulators and innovators to experiment safely, test ethical parameters, and refine best practices before scaling up.
India’s goal is not just to regulate AI but to humanise it, to ensure technology amplifies public good rather than deepening divides. Embedding ethical and technical discipline into AI foundations will help India build a trusted innovation ecosystem that attracts responsible investment, global collaboration, and skilled talent. It would also reinforce consumer and investor confidence while curbing the risk of systemic failures.
The transition, however, comes with trade-offs: higher compliance costs, the need for algorithm-audit expertise, and tighter coordination among regulators. Yet these are the necessary costs of digital maturity. The alternative of fragmented oversight and unchecked algorithmic dominance, would be far costlier, eroding both trust and stability.
Ultimately, India’s challenge is to balance innovation with integrity. The test of AI leadership will lie not in how much intelligence we create, but in how wisely we govern it, turning algorithms from instruments of advantage into enablers of equity.