"Bachat ab darr nahi, taakat hai."
"Ab humari bachat, humari sharton par."
"Hum saath aaye, toh system badal gaya."
"Bank nahi, hum khud apne banker."
"Jo liya gaya, woh wapas milega — aur zyada."
"Bachat ab darr nahi, taakat hai."
"Ab humari bachat, humari sharton par."
"Hum saath aaye, toh system badal gaya."
"Bank nahi, hum khud apne banker."
"Jo liya gaya, woh wapas milega — aur zyada."
RBI Innovation Hub · Retail CBDC Sandbox · 2026

A Regulatory Framework
Built for Sovereign Finance

Flenbox is a non-custodial, zero-sum programmable payment protocol built natively on RBI's retail CBDC (e₹). Every design decision — pool architecture, settlement mechanics, KYC flow, TDS logic — was made with the regulator in mind.

This page summarises the regulatory highlights of our 27-page RBI sandbox submission for review by RBI officials, bank partners, and compliance teams.

Submission Reference
CompanyFlenbox Technologies Pvt Limited
CINU62099MH2026PTC465568
Incorporated15 January 2026 · Mumbai
Submission ToRBI Innovation Hub · Retail CBDC Sandbox
Bank SponsorIDFC First Bank (discussions active)
Regulatory Contactrbi@flenbox.com
Application In Progress · 2026

What Flenbox Is and Is Not

Regulatory classification is unambiguous. Flenbox does not require an NBFC licence, does not fall under the Chit Funds Act, and holds no user funds.

✗  Flenbox Is NOT
  • ✗ A bank or NBFC — does not take deposits
  • ✗ A chit fund — does not fall under Chit Funds Act 1982
  • ✗ A lending platform — zero lending activity, zero NPA risk
  • ✗ A custodian — never holds or moves user funds directly
  • ✗ A crypto platform — no private tokens, no DLT, no wallets
  • ✗ A payment aggregator — does not aggregate payments for merchants
  • ✗ Generating yield — no external interest income redistributed
✓  Flenbox IS
  • ✓ A programmable payment coordination protocol on RBI e₹
  • ✓ A zero-sum group commitment platform — closed system math
  • ✓ Non-custodial — user funds remain in their own bank wallets
  • ✓ A technology services company — earns platform fees only
  • ✓ KYC-compliant — full Aadhaar e-KYC via bank partner APIs
  • ✓ TDS-compliant — Section 194R deduction on bonus above ₹5,000
  • ✓ DPDP Act compliant — no user financial data sold or shared

Regulatory Design Decisions

Every framework decision was made proactively — not reactively.

🏛️
RBI CBDC Native Settlement
All group distributions execute on RBI's retail CBDC infrastructure — the e₹. Atomic finality. Immutable transaction logs. Sovereign guarantee on every rupee settled.
Aligned: RBI CBDC Concept Note 2022, Section 4.2 — Programmable Payments
🔒
Non-Custodial Architecture
User funds never transfer to Flenbox. e₹ remains in each user's own bank wallet at all times. Flenbox issues programmatic instructions to e₹ infrastructure — it does not hold a balance.
Aligned: RBI Payment Aggregator Guidelines 2021 — Non-aggregation of settlement funds
⚖️
Zero-Sum Mechanics — No Yield Generation
Total committed e₹ is reallocated within the group. Nothing added from outside. Nothing lent. No interest income. Surplus arises solely from bid differential — a closed mathematical system.
Aligned: Not classified as deposit-taking under RBI Act 1934, Section 45-I(bb)
🪪
KYC & AML Framework
Full Aadhaar e-KYC via bank partner API before group activation. PAN linking for TDS. Transaction monitoring via AI anomaly detection. Suspicious transaction reporting per PMLA 2002.
Aligned: RBI KYC Master Direction 2016 (updated 2023)
📋
TDS & GST Compliance
TDS at 10% deducted automatically on bonus payouts exceeding ₹5,000/year under Section 194R. Platform fees subject to 18% GST. All deductions computed programmatically. Form 26Q filed quarterly.
Aligned: Income Tax Act 1961, Section 194R — Benefits or perquisites
🛡️
Programmable Reserve — Pool C
50% of end-of-cycle surplus plus G-sec yields accumulated in a programmable risk reserve. Released only on verified fraud or missed payment triggers. Self-sustaining across cycles.
Aligned: RBI Prudential Framework — internal risk buffers for fintech entities
📊
G-Sec Custodianship
Pool A committed e₹ invested in Government Securities under bank or RBI custodianship. IDFC First Bank in active discussions as G-sec custodian and e₹ wallet integration partner.
Aligned: RBI Government Securities Act 2006 — custodian arrangements
🔐
Data Protection — DPDP Act 2023
User financial behaviour data used solely for AI matrix profiling within the platform. Never sold. Never shared with advertisers. Consent obtained at onboarding. Right to erasure honoured.
Aligned: Digital Personal Data Protection Act 2023 — Data Fiduciary obligations

Three-Pool Architecture

Every rupee collected is accounted for. Zero leakage. Full auditability at every cycle position.

A
Commitment Pool
  • Month 1 user commitments + FBOSS anchor
  • Invested in G-sec — sovereign, zero market risk
  • Bank / RBI as G-sec custodian
  • Declining balance as monthly payouts are made
  • G-sec yields flow to Pool C reserve
  • Fully auditable per cycle per member
B
Revenue Pool
  • Flat enrollment fee — one-time per group join
  • 1–2% variable transaction fee per cycle
  • 100% retained by Flenbox Technologies
  • Funds operations and growth
  • Subject to 18% GST — invoiced transparently
  • No redistribution to users from Pool B
C
Reserve Pool
  • 50% of end-of-cycle surplus after all payouts
  • G-sec yields from Pool A investment
  • Penalty income from forced exits / litigation
  • Programmable escrow — conditional release only
  • Grows across cycles — self-healing reserve
  • No external bailout ever required

RBI CBDC Policy Alignment

Point-by-point alignment with RBI's stated CBDC objectives and the 2022 Concept Note.

RBI CBDC ObjectiveFlenbox PositionStatus
Financial inclusion for underserved populationsCore mission — 70Cr+ Indians targeted. Entry at ₹1,000/month. Behaviour score not CIBIL.Aligned
Programmable payments on e₹ infrastructureAll distributions are programmatic — triggered by cycle completion, bid outcome, KYC verification.Aligned
Reduce cash usage in informal economiesReplaces informal cash-based group savings (₹1.5T+ market) with fully digital sovereign currency transactions.Aligned
No disintermediation of commercial banksBank remains the e₹ wallet custodian. Flenbox integrates with bank APIs — does not replace the bank relationship.Aligned
Sovereign guarantee on digital currencyAll user funds remain in e₹ — RBI sovereign guarantee applies at every point. No exposure to private tokens.Aligned
Consumer data protectionDPDP Act 2023 compliant. No data sold. Consent-based profiling only. Right to erasure implemented.Aligned
Interoperability with existing payment systemse₹ wallet integration via IDFC First / ICICI APIs. Designed to work alongside UPI — not replace it.Aligned
Blockchain / DLT requirementNot applicable — Flenbox uses RBI's centralised e₹ ledger. No decentralised risk.N/A

Simulation Audit Summary

Full cycle simulations verified. Zero-sum integrity confirmed. Variance is floating-point rounding only.

M1 Scheme
₹10,000 / month tier
Total Input₹9,10,000
Total Distributed₹9,09,999.96
Variance₹0.04
TDS (net profit > ₹5K)₹700.00 deducted
Effective return (patient)~10.4%
Variance of ₹0.04 on ₹9,10,000 = floating point rounding. Zero logic error confirmed.
M2 Scheme
₹10,000 / month tier
Total Input₹9,61,600
Total Distributed₹9,61,599.97
Variance₹0.03
TDS (net profit > ₹5K)₹700.00 deducted
Effective return (patient)~10.4%
Variance of ₹0.03 on ₹9,61,600 = floating point rounding. Zero-sum integrity verified.
M1 Scheme
₹5,000 / month tier
Total Input₹4,55,000
Total Distributed₹4,54,999.96
Variance₹0.04
TDS (net profit < ₹5K)₹0.00 — below threshold
Effective return (patient)~7.7%
Net profit ₹3,500 at ₹5K tier — below ₹5,000 TDS threshold. No deduction applied correctly.
M2 Scheme
₹5,000 / month tier
Total Input₹4,80,800
Total Distributed₹4,80,799.96
Variance₹0.04
TDS (net profit < ₹5K)₹0.00 — below threshold
Effective return (patient)~7.7%
All four simulations confirm: zero-sum holds across every cycle position.

Contact the Regulatory Team

For RBI officials, bank compliance teams, DPIIT reviewers, or any regulatory enquiry. All communications treated with highest confidentiality.

Vinod Dhawle handles all regulatory correspondence personally. Response within 24 hours on working days.

Founder & Regulatory Contact
Vinod Dhawle
Director, Flenbox Technologies Pvt Limited
rbi@flenbox.com
Registered Office
Flenbox Technologies Pvt Limited
CIN: U62099MH2026PTC465568
Mumbai, Maharashtra, India · Incorporated: 15 January 2026
Bank Partner — Active Discussion
IDFC First Bank
G-Sec custodianship · e₹ wallet integration · RBI sandbox bank sponsor

All regulatory correspondence handled with strict confidentiality.

🏛️
Enquiry received.
Vinod will respond within 24 hours. For urgent matters: rbi@flenbox.com