Karsten Wenzlaff, Advisor
August 26th, 2025
August 11, 2026 | NCFA Insight | Artificial Intelligence And Data, Cross Border Payments And FX, Regulation And Policy

On August 11, 2026, RBI Governor Sanjay Malhotra called for stronger bank AI governance while confirming that BRICS members are discussing links between fast payment systems and central bank digital currencies.
Malhotra urged Indian banks to inventory the AI models they use and establish board approved AI governance policies, while arguing that banks cannot afford to avoid the technology because of its risks. The BRICS discussion is less advanced, but it has progressed beyond India's proposal earlier this year.
The RBI has been working toward this point for some time. India's FREE-AI framework was developed around responsible AI use in finance, including governance, explainability, privacy, fairness and risk controls. The central bank has also been expanding its model risk work beyond credit models into other operating areas.
Malhotra's August remarks make the institutional responsibility clearer. A bank cannot govern AI well if it cannot identify which models are running, where they are used or who owns the decisions around them. An inventory creates the starting record. Board approved governance then establishes responsibility above individual technology teams.
That becomes more important as AI spreads beyond analysis into customer service, credit, fraud detection, risk management and other live banking functions. Cybersecurity and operational risk also grow with the number of systems, vendors and data connections involved.
Canada is dealing with more or less the same operating problem. OSFI and GRI's financial AI work found that regulated deployment depends on practical controls around identity, cyber risk, financial crime, third party providers and customer outcomes. More than 170 participants contributed to that work, with 72% reporting AI use at work in financial services.
Financial regulators are asking institutions to prove control over AI that is already being used. For banks, model inventories, ownership, monitoring and escalation are becoming part of normal operating discipline.
The payments comments are at an earlier stage.
In January, India proposed that BRICS members consider linking their official digital currencies for cross border trade and tourism payments. NCFA captured that proposal in its January BRICS payments evidence.
Malhotra now says BRICS members are discussing potential links between both fast payment systems and CBDCs. The objective is lower cost cross border payments, but he was equally clear that the work is still at the discussion stage.
There is no shared BRICS CBDC network, agreed settlement architecture or implementation timetable. There is also no basis for treating the discussions as evidence that a common BRICS currency is being created. Official BRICS material has instead focused on reducing the cost of trade and financial transactions and improving payment links between member countries.
The addition of fast payment systems is also important. CBDCs are only one possible route. Connecting existing national payment rails may offer another way to improve cross border transfers without waiting for every participating country to deploy a mature digital currency.
Malhotra did not present AI governance and BRICS payment connectivity as a single program, however combined they do expose a common operating issue. Inside a bank, more capable AI requires clearer ownership, controls and auditability. Between countries, more connected payment systems require agreements around access, standards, settlement, legal responsibility and risk.
Interoperability is useful only when participants know who is accountable when something fails. The same is true for AI performing more important financial work.
For Canadian readers, the comparison is timely. Canada's financial infrastructure is becoming more open through new payment system access, PSP supervision and the Real Time Rail, while banks are also deploying more AI. Different technologies are involved, but both require stronger operating controls as access and automation expand.
Financial infrastructure gets harder to govern as it becomes more capable and connected. The RBI's AI expectations and the BRICS payment discussions show that control, accountability and interoperability are becoming operating questions, not side issues for innovation teams.
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