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Twenty-four Asks of the RBI: A Detailed Comment on the 2026 Model Risk Management Draft
A clause-by-clause comment record on the RBI's 2026 draft Guidance on Model Risk Management. Proportionality, definitions, the black-box validation problem at paragraph 46, kill-switch operationalisation, DPDPA interaction, and a phased 18, 24, 36 month rollout. Twenty-four asks in one place.
Sushant Shukla
Contributor
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22 min read
From Credit Models to Frontier AI: Inside the RBI's 2026 Draft Guidance on Model Risk Management
The RBI's draft Guidance on Model Risk Management, 2026 puts every model used by India's banks, NBFCs and FIs, statistical, algorithmic and AI alike, under a single Board-owned framework, and writes the regulator's first detailed AI rulebook. A clause-by-clause analysis.
Sushant Shukla
Contributor