Dvara Research1 is an independent Indian not-for-profit research institution guided by our mission of ensuring that every individual and every enterprise has complete access to financial services. Our work seeks to address challenges for policy and regulation in India including in the waves of digital innovation sweeping financial services, focussing on the impact on lower income individuals in the country. The regulation of personal data and public digital infrastructure have been core areas of our recent research. In this document, we present our response to the White Paper on the Strategy for National Open Digital Ecosystems (the White Paper) released by the Ministry of Electronics and Information Technology (MeitY) in February 2020. We are deeply concerned that creating National Open Digital Ecosystems (NODEs) as envisioned in the White Paper could entrench existing problems with service delivery and hamper the growth of a free and fair digital economy. The assumptions, principles and strategies underlying NODEs merit re-consideration. To begin a constructive conversations on these issues, we present research and responses to public consultation in this document in two sections
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