While the proposed ODR system seems to be a hopeful path for “boosting digital payments and enhancing the broader financial ecosystem“, the issues that may arise out of it must not be overlooked:
Firstly, the links between the various modes of lodging complaints must be analyzed, improper communications between the modes and the PSOs may create distortions and thus lead to ambiguities, which may have severe consequences.
Secondly, in an attempt to protect data or private information related to a customer, if the RBI creates a design that is too intricate or intertwined, it may complicate the overall process not just for the PSOs and PSPs but also for the customers.
Finally, in the event that a unique reference code does not function due to some technicality, the customer would have to go through another round of complaint lodging in order to understand the status of his case. This back and forth process may lead to customers losing trust in such a mechanism, thereby forcing them to shy away from making such payments online.
These are only a few indicative issues; however, there may be many more. It is too early to judge the validity of such an ODR system. All one can do now is be hopeful that the RBI keeps such technical issues in mind while designing an appropriate system to compliment the positive attributes it serves and come up with an effective system for an online dispute resolution to successfully cater to the disputes and grievances of its customers.
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