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The New Architecture of Work: Decoding the Full Operationalization of India’s Four Labour Codes

By Adv. Amarjeet Singh, Founder, PRAN – Policy Research Action Network Foundation

India has entered a decisive new phase in its labour governance architecture. With the Union Government notifying the final operational rules under the four Labour Codes in 2026, the country has formally completed one of the most significant labour law restructurings since Independence.

Replacing 29 central labour legislations with four consolidated codes, the reform impacts wages, industrial relations, social security, and workplace safety across an economy employing over 500 million workers. The government presents the transition as a move away from the compliance-heavy “Inspector Raj” toward a streamlined, technology-driven labour governance system aligned with the needs of a modern economy.

Yet beneath the language of reform lies a deeper constitutional and socio-economic question:

Can India modernize its labour market without weakening the protections that labour laws were originally designed to secure?

The answer to that question will shape the future of work, industrial relations, and social justice in India for decades.


From Welfare-State Labour Protection to Compliance-State Governance

India’s earlier labour law architecture emerged from a post-independence welfare-state philosophy rooted in constitutional guarantees of dignity, livelihood, equality, and humane working conditions.

The framers of India’s labour jurisprudence understood that labour is not merely an economic input but a human constituency requiring protection against structural inequality.

This constitutional vision has repeatedly been affirmed by the judiciary.

In Bandhua Mukti Morcha v. Union of India, the Supreme Court recognized bonded labour and exploitative work conditions as violations of fundamental rights under Articles 21 and 23.

In Olga Tellis v. Bombay Municipal Corporation, the Court expanded Article 21 to include the right to livelihood.

Similarly, People’s Union for Democratic Rights v. Union of India reinforced that exploitative labour practices violate constitutional guarantees against forced labour.

The new Labour Codes represent a major shift from this traditional protection-centric approach toward:

  • self-certification,
  • digitized compliance,
  • centralized filings,
  • reduced inspector discretion,
  • and greater employer flexibility.

This transition reflects India’s broader economic strategy:

  • manufacturing-led growth,
  • global supply-chain integration,
  • foreign investment attraction,
  • and industrial competitiveness.

The Four Labour Codes: India’s New Industrial Constitution

1. Code on Wages, 2019

The Wage Code universalizes minimum wage protection across sectors while introducing a statutory national “floor wage.”

A major structural change is the revised definition of “wages,” under which basic pay and dearness allowance must ordinarily constitute at least 50% of total remuneration.

This directly affects:

  • Provident Fund contributions,
  • gratuity,
  • bonuses,
  • and ESI calculations.

For workers, this may mean:

  • lower immediate take-home salaries,
  • but higher long-term retirement and social security benefits.

The Code also mandates:

  • digital wage payments,
  • electronic wage slips,
  • and standardized wage calculations.

The digitization of payroll systems is expected to improve transparency and reduce under-reporting of statutory liabilities.


2. Code on Social Security, 2020

This Code is arguably the most ambitious component of the reform package.

For the first time, Indian labour legislation formally recognizes:

  • gig workers,
  • platform workers,
  • and sections of the informal economy within a social security framework.

India’s gig economy is projected to employ millions across:

  • food delivery,
  • transport aggregation,
  • logistics,
  • home services,
  • and digital freelancing.

The Code attempts to extend:

  • insurance,
  • pension access,
  • maternity support,
  • disability benefits,
  • and welfare schemes to these workers.

However, implementation remains deeply uncertain.

India still lacks:

  • a comprehensive worker registry,
  • portable benefit architecture,
  • standardized contribution systems,
  • and clear rules defining platform liability.

Without enforceable funding mechanisms and interoperable digital infrastructure, social security protections risk remaining largely symbolic.


3. Industrial Relations Code, 2020

The Industrial Relations Code fundamentally restructures the balance between labour flexibility and worker protection.

Key changes include:

  • legal recognition of fixed-term employment,
  • revised strike procedures,
  • changes in union recognition requirements,
  • and higher thresholds for government approval before layoffs or retrenchment.

The increase in thresholds from 100 to 300 workers for mandatory government permission before layoffs is among the most debated reforms.

Supporters argue this:

  • encourages manufacturing expansion,
  • reduces regulatory fear,
  • and improves ease of doing business.

Critics argue it weakens employment security for workers in medium-sized enterprises and may accelerate contractualization of labour.

Trade unions have also raised concerns that stricter strike procedures could reduce the practical ability of workers to collectively negotiate workplace conditions.


4. Occupational Safety, Health and Working Conditions Code, 2020

The Occupational Safety Code consolidates laws governing:

  • factories,
  • contract labour,
  • migrant workers,
  • mines,
  • plantations,
  • and industrial establishments.

It introduces:

  • unified licensing,
  • standardized safety norms,
  • digitized compliance systems,
  • and expanded employer obligations.

The Code also permits women to work in all sectors and night shifts subject to safeguards and consent-based conditions.

While framed as gender inclusion, this raises critical implementation questions:

  • workplace transport safety,
  • sexual harassment prevention,
  • grievance redressal,
  • and enforcement in smaller establishments remain uneven across states.

India’s Informal Labour Reality

Any discussion of labour reform in India must confront one uncomfortable reality:

India remains overwhelmingly informal.

A substantial majority of Indian workers remain outside formal contractual employment structures.

This includes:

  • construction workers,
  • domestic workers,
  • sanitation workers,
  • warehouse labour,
  • street vendors,
  • migrant workers,
  • and platform-based delivery workers.

For millions of workers, labour exploitation is not theoretical.

It manifests through:

  • delayed wages,
  • unsafe workplaces,
  • lack of contracts,
  • absence of social security,
  • excessive work hours,
  • and barriers to legal remedies.

The true success or failure of the Labour Codes will therefore not be judged in boardrooms or policy conferences—but in the everyday conditions experienced by India’s working population.


The End of “Inspector Raj” — Or the Rise of Invisible Enforcement?

The government has repeatedly framed the Labour Codes as dismantling the old “Inspector Raj” model.

Under the new system:

  • inspections are increasingly digitized,
  • filings are centralized,
  • compliance is automated,
  • and risk-based inspections replace discretionary physical oversight.

This may reduce corruption and bureaucratic harassment.

However, it also raises a critical concern:

Can digital compliance systems effectively regulate highly informal labour markets?

In sectors such as:

  • construction,
  • logistics,
  • warehousing,
  • garment manufacturing,
  • and platform work,

formal compliance often exists only on paper.

The danger is that algorithmic governance may create:

  • cleaner records,
  • improved dashboards,
  • and statistical compliance—

while exploitative conditions continue invisibly on the ground.


The Rise of Algorithmic Labour Governance

Globally, labour regulation is increasingly confronting a new challenge:

algorithmic management.

In platform-based economies, workers are often governed not by human supervisors but by:

  • app-based ratings,
  • automated scheduling,
  • productivity tracking,
  • dynamic penalties,
  • and opaque algorithmic systems.

Delivery workers and ride-share drivers frequently report:

  • arbitrary deactivations,
  • unpredictable earnings,
  • surveillance-based productivity pressure,
  • and lack of transparency in work allocation.

India’s Labour Codes do not yet adequately address:

  • algorithmic accountability,
  • platform transparency,
  • digital surveillance,
  • or automated employment decision-making.

This may become the defining labour rights issue of the next decade.


The Global Supply Chain Context

India’s labour reforms are also linked to a larger geopolitical and economic transition.

As multinational corporations diversify supply chains away from China, countries such as:

  • Vietnam,
  • Indonesia,
  • Bangladesh,
  • and India

are competing aggressively for manufacturing investment.

Flexible labour systems are increasingly viewed as essential for:

  • export competitiveness,
  • industrial scaling,
  • and global manufacturing integration.

India’s Labour Codes are therefore not only domestic legal reforms—they are instruments of economic positioning within global capitalism.

The policy dilemma is clear:

How does India attract investment without triggering a race to the bottom in labour protections?


Trade Union Resistance and the Crisis of Labour Representation

Trade unions across India have opposed several aspects of the Codes since their introduction.

Their concerns include:

  • dilution of strike rights,
  • weakening of collective bargaining,
  • increased contractualization,
  • and reduced job security.

But the reforms also expose a deeper structural problem:

traditional labour representation itself is weakening.

India’s workforce is increasingly fragmented into:

  • temporary workers,
  • outsourced labour,
  • contractual staff,
  • platform workers,
  • and digitally managed gig labour.

Many workers now operate outside traditional union structures altogether.

This raises a central policy challenge for the future:

How can labour rights be protected when stable long-term employment itself is declining?


Federalism and the State-Level Challenge

Labour falls within the Concurrent List of the Constitution, meaning both the Union and states exercise legislative authority.

As a result, implementation will vary significantly across states depending on:

  • administrative capacity,
  • political priorities,
  • industrial policy,
  • and digital readiness.

This creates the possibility of:

  • uneven enforcement,
  • labour migration distortions,
  • and competitive deregulation among states seeking investment.

India may ultimately evolve not into one unified labour market—
but into multiple labour governance ecosystems.


PRAN Policy Recommendations

At PRAN, we believe labour reform cannot be assessed solely through the lens of economic efficiency.

The true benchmark must be whether reform strengthens:

  • dignity,
  • fairness,
  • social protection,
  • and constitutional justice.

PRAN recommends the following urgent policy interventions:

1. National Gig Worker Registry

Create a centralized, portable worker identification system linked to social security benefits.

2. Inflation-Indexed Dynamic Floor Wage

Ensure periodic automatic revision of floor wages based on inflation and regional living costs.

3. Independent Digital Labour Audit Authority

Establish an independent oversight body to audit digital compliance systems and algorithmic labour governance.

4. Portable Social Security Architecture

Enable workers to retain benefits across states, sectors, and employment platforms.

5. Algorithmic Transparency Rules

Mandate disclosure standards for platform-based worker management systems.

6. Labour Rights Ombudsman System

Create accessible grievance mechanisms for informal and gig workers.

7. Annual Parliamentary Labour Impact Review

Institutionalize annual public reporting on:

  • wage trends,
  • workplace safety,
  • gig economy conditions,
  • and labour rights enforcement.

Conclusion: India’s Largest Socio-Economic Experiment

The operationalization of the Labour Codes marks the beginning of a transformative new industrial era.

Supporters see:

  • modernization,
  • investment growth,
  • formalization,
  • and regulatory efficiency.

Critics see:

  • precarious employment,
  • weakened worker protections,
  • and expanding asymmetry between labour and capital.

Both perspectives contain elements of truth.

India is now undertaking one of the world’s largest real-time experiments in balancing:

  • economic competitiveness,
  • industrial growth,
  • technological governance,
  • and labour dignity.

The true measure of these reforms will not be investor confidence alone.

It will be whether the workers powering India’s economic rise are treated merely as disposable inputs in a production system—
or as constitutional citizens entitled to dignity, security, livelihood, and justice.


About PRAN

ЁЯМР PRAN – Policy Research Action Network Foundation

PRAN works on public policy, labour rights, governance reform, consumer protection, and access to justice through legal analysis, advocacy, and institutional engagement.


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Insurance Claims Cannot Be Rejected on Mere Allegations: Delhi Consumer Commission Reinforces Consumer Rights

By Adv. Amarjeet Singh, Founder, PRAN – Policy Research Action Network Foundation

Introduction

In a significant consumer protection ruling, the Delhi State Consumer Disputes Redressal Commission has once again reminded insurance companies that policy repudiation cannot be based on suspicion, assumptions, or vague allegations of “pre-existing disease.” The Commission directed an insurer to pay ₹20 lakh along with compensation and litigation costs after finding that the rejection of a life insurance claim lacked credible evidence.

The judgment is important not only for insurance law but also for the broader debate around accountability in India’s financial and insurance sectors. Across the country, consumers frequently face claim denials on technical grounds after years of paying premiums in good faith. This case highlights how consumer forums are increasingly scrutinising arbitrary repudiation practices.

Background of the Case

The matter involved a life insurance claim filed by the widow of a deceased policyholder. The insurer rejected the claim alleging that the insured had suppressed information regarding a pre-existing medical condition at the time of purchasing the policy.

According to the insurer:

  • the deceased allegedly suffered from diabetes before obtaining the policy,

  • and this fact was not disclosed in the proposal form.

The insurer attempted to justify repudiation through an investigation report and selective medical references.

However, the Delhi State Commission found serious weaknesses in the insurer’s case.

What the Delhi State Commission Held

The Commission observed that:

  • the insurer failed to produce reliable and conclusive evidence proving deliberate concealment,

  • the investigation report was contradictory and largely hearsay-based,

  • and there was no proper proof that the alleged pre-existing disease directly caused or contributed to the death.

Importantly, the Commission clarified that:

Mere allegations or assumptions regarding pre-existing illness cannot become grounds for denial of insurance benefits.

The Commission also noted procedural concerns, including:

  • delay in claim repudiation,

  • failure to establish that policy terms were properly supplied,

  • and absence of convincing medical evidence from the period before policy issuance.

As a result, the Commission ordered:

  • payment of the insured amount of ₹20 lakh,

  • interest at 6%,

  • ₹1 lakh compensation for mental agony,

  • and litigation costs.

The Growing Problem of Arbitrary Insurance Claim Rejections

This case reflects a larger systemic issue affecting consumers across India.

Many insurance companies routinely invoke:

  • “non-disclosure,”

  • “suppression of material facts,”

  • or “pre-existing disease”

to reject claims after hospitalization or death.

Frequently targeted conditions include:

  • diabetes,

  • hypertension,

  • cardiac ailments,

  • kidney disease,

  • or other lifestyle-related illnesses.

In many cases:

  • no medical examination was conducted before issuing the policy,

  • the insurer accepted premiums for years,

  • and repudiation occurs only after a claim is filed.

This creates a deeply unequal situation where insurers enjoy the benefits of premium collection while consumers and their families bear the burden of prolonged litigation.

Consumer Protection Principles Reinforced

The ruling reinforces several important legal principles:

1. Burden of Proof Lies on the Insurer

If an insurance company alleges suppression or concealment, it must prove:

  • that the insured knew about the illness,

  • deliberately concealed it,

  • and that the illness was material to the policy.

Suspicion alone is insufficient.

2. Lifestyle Diseases Cannot Automatically Defeat Claims

Conditions like diabetes or hypertension are increasingly common in India. Consumer forums are recognising that insurers cannot use generalized assumptions to reject claims without direct medical evidence.

3. Investigation Reports Must Be Credible

Consumer commissions are becoming more critical of private investigation reports that rely on:

  • hearsay,

  • neighborhood statements,

  • unsupported assumptions,

  • or contradictory findings.

4. Insurance Contracts Must Be Transparent

Insurers cannot rely upon undisclosed clauses or vague policy conditions after accepting premiums.


Broader Regulatory and Policy Concerns

This case also raises important policy questions for India’s insurance ecosystem.

Should insurers be allowed to reject claims after skipping pre-policy medical tests?

If an insurer issues a high-value policy without conducting adequate medical screening, it becomes unfair to later accuse consumers of concealment without strong proof.

Is there sufficient regulatory oversight on repudiation practices?

Insurance claim rejection remains one of the most common consumer grievances in India. There is growing need for:

  • stricter IRDAI oversight,

  • transparent repudiation standards,

  • mandatory disclosure accountability on insurers,

  • and stronger penalties for arbitrary denials.

Access to Justice Remains Unequal

Many consumers:

  • lack legal awareness,

  • cannot afford prolonged litigation,

  • or abandon valid claims due to financial stress.

Consumer commissions therefore play a critical role in balancing power between corporations and ordinary policyholders.

What Consumers Should Do

Consumers purchasing insurance policies should:

Before Buying a Policy

  • honestly disclose known medical conditions,

  • carefully review proposal forms,

  • keep copies of all submitted documents,

  • and avoid signing blank forms.

During the Policy Period

  • preserve premium receipts,

  • maintain medical records,

  • and document all insurer communications.

If a Claim is Rejected

  • demand written reasons for repudiation,

  • seek complete policy and investigation records,

  • file grievance complaints before the insurer and IRDAI or Ombudsman

  • and approach consumer commissions where necessary.

PRAN’s Perspective

At PRAN Foundation, we believe that insurance exists to provide financial protection during moments of crisis—not to become a mechanism for post-claim technical avoidance.

Consumer trust in the insurance sector depends on:

  • transparency,

  • fair dealing,

  • accountability,

  • and ethical claims processing.

When companies reject claims without adequate proof, it not only harms individual families but also weakens public confidence in the entire insurance system.

The Delhi State Commission’s ruling sends an important message:

insurance contracts cannot operate as one-sided instruments where corporations collect premiums comfortably but evade responsibility when claims arise.

Consumer rights jurisprudence in India must continue evolving toward substantive fairness rather than procedural technicalities.

Conclusion

The Delhi State Commission’s judgment is a significant reaffirmation of consumer protection principles in insurance disputes. It strengthens the idea that insurers cannot deny legitimate claims merely by invoking vague allegations of pre-existing disease without clear and credible evidence.

As insurance penetration expands in India, the need for fair claim settlement practices becomes even more critical. Regulatory institutions, consumer forums, and civil society must continue ensuring that insurance serves its intended purpose: financial security and social protection—not corporate evasion.

Case Reference

MS. SUNITA KAIN vs. INDIA FIRST LIFE INSURANCE COMPANY LTD.
First Appeal No. 237/2023
Delhi State Consumer Disputes Redressal Commission

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Hindi Summary (рд╣िंрджी рд╕ाрд░)

рджिрд▓्рд▓ी рд░ाрдЬ्рдп рдЙрдкрднोрдХ्рддा рдЖрдпोрдЧ рдиे рдПрдХ рдорд╣рдд्рд╡рдкूрд░्рдг рдлैрд╕рд▓े рдоें рдХрд╣ा рдХि рдмीрдоा рдХंрдкрдиिрдпां рдХेрд╡рд▓ “рдкूрд░्рд╡-рд╡िрдж्рдпрдоाрди рдмीрдоाрд░ी” (Pre-existing Disease) рдХा рдЖрд░ोрдк рд▓рдЧाрдХрд░ рдмीрдоा рджाрд╡ा рдЦाрд░िрдЬ рдирд╣ीं рдХрд░ рд╕рдХрддीं, рдЬрдм рддрдХ рдЙрд╕рдХे рд╕рдорд░्рдерди рдоें рдаोрд╕ рдФрд░ рд╡िрд╢्рд╡рд╕рдиीрдп рдк्рд░рдоाрдг рди рд╣ों।

рдЖрдпोрдЧ рдиे рдкाрдпा рдХि:

  • рдмीрдоा рдХंрдкрдиी рдкрд░्рдпाрдк्рдд рдоेрдбिрдХрд▓ рд╕рдмूрдд рдкेрд╢ рдирд╣ीं рдХрд░ рд╕рдХी,

  • рдЬांрдЪ рд░िрдкोрд░्рдЯ рд╡िрд░ोрдзाрднाрд╕ी рдФрд░ рдХрдордЬोрд░ рдеी,

  • рддрдеा рдмीрдоाрд░ी рдФрд░ рдоृрдд्рдпु рдХे рдмीрдЪ рд╕्рдкрд╖्рдЯ рд╕ंрдмंрдз рд╕ाрдмिрдд рдирд╣ीं рдХिрдпा рдЧрдпा।

рдЖрдпोрдЧ рдиे рдмीрдоा рдХंрдкрдиी рдХो:

  • ₹20 рд▓ाрдЦ рдмीрдоा рд░ाрд╢ि,

  • рдм्рдпाрдЬ,

  • рдоाрдирд╕िрдХ рдкीрдб़ा рд╣ेрддु рдоुрдЖрд╡рдЬा,

  • рддрдеा рдоुрдХрджрдоे рдХा рдЦрд░्рдЪ рджेрдиे рдХा рдиिрд░्рджेрд╢ рджिрдпा।

рдпрд╣ рдлैрд╕рд▓ा рдЙрдкрднोрдХ्рддा рдЕрдзिрдХाрд░ों рдФрд░ рдмीрдоा рдХ्рд╖ेрдд्рд░ рдоें рдЬрд╡ाрдмрджेрд╣ी рдХो рдордЬрдмूрдд рдХрд░рддा рд╣ै।


Disclaimer

This article is intended for public legal awareness and policy discussion purposes only. It does not constitute legal advice. Readers facing specific disputes should seek appropriate professional legal assistance.


Call to Action

Facing unfair insurance claim rejection or consumer rights violation?

PRAN Foundation’s Consumer Rights Expert Desk supports complex consumer disputes involving:

  • insurance claims,

  • financial services,

  • unfair trade practices,

  • digital fraud,

  • and regulatory grievances.

For institutional referrals, collaborations, or legal-policy support, connect with PRAN Foundation.

#ConsumerRights #InsuranceClaims #InsuranceLaw #ConsumerProtection #DelhiConsumerCommission #IRDAI #FinancialJustice #PolicyResearch #LegalAwareness #PRANFoundation #AccessToJustice #ConsumerLaw #InsuranceSector #PublicInterest #JusticeForConsumers

Imagine Paying Your Credit card Bill on Time, But Being Treated Like a Defaulter

By Amarjeet Singh, Advocate- PRAN Foundation 04 May 2026

Imagine doing everything right. You pay your credit card bill on time through a popular app. You see the "Success" screen. You go about your life.

Then, a year later, you wake up to find your savings account frozen, your credit score in tatters, and a premium credit card application rejected. You’ve been branded a "defaulter" for a bill you paid 14 months ago.

This isn't a horror story. It is the real-life battle of a consumer supported by PRAN Foundation, and it reveals a terrifying truth: In India’s digital payment boom, the "system" is rigged against the consumer when things go wrong.


The Nightmare: A Timeline of Systemic Failure

In March 2025, our client paid his monthly credit card bill to HDFC Bank via MobiKwik (routed through ZAVO).

  • The Glitch: The money left his bank, but never reached his credit card.

  • The Harassment: For a year, the bank piled on interest, late fees, and GST.

  • The Seizure: In 2026, the bank used its "lien" power to unilaterally snatch from his personal savings account to cover the disputed debt.

  • The Blacklist: The bank reported him to CIBIL, tanking his reputation and blocking his access to future credit.

Despite dozens of emails and proof of payment, the bank and the apps played "pass the buck." The bank blamed the app; the app blamed the intermediary; the intermediary eventually refunded the money without consent, leaving the consumer in a legal lurch.


PRAN Foundation Strikes Back: The ₹20 Lakh Legal Notice

When "Customer Care" becomes a circular room of automated replies, legal action is the only exit.

PRAN Foundation didn't just ask for a refund. We issued a formal Legal Notice to HDFC Bank, MobiKwik, and ZAVO. Our legal desk, backed by decades of consumer advocacy experience, is demanding:

  1. Immediate Restoration of the CIBIL score.

  2. Full Refund of all illegally seized funds and penalties.

  3. ₹20 Lakh in Compensation for mental agony, harassment, and the loss of financial opportunities.

Why This Matters to YOU: The 3 "Digital Traps"

This case isn't just about one person. It exposes three massive gaps in India's regulatory architecture:

1. The "Ghost Payment" Loophole

There is currently no law that says who is automatically liable when a BBPS payment fails. You are left to fight three billion-dollar companies at once.

PRAN Advocacy: We are calling for a "Single Point of Liability"—once you get a receipt, the bank must handle the backend mess, not you.

2. The Illegal "Lien" Weapon

Banks are using "set-off" powers to grab money from savings accounts even while a dispute is being investigated by the RBI Ombudsman.

PRAN Advocacy: This is coercive. We are pushing for an absolute ban on seizing funds for transactions currently under dispute.

3. Credit Reporting as Blackmail

Banks report you to CIBIL the moment a glitch happens, using your financial reputation as leverage to force you to pay wrongful charges.

PRAN Advocacy: We propose a "Dispute Flag" on CIBIL reports that freezes your score impact until the investigation is over.

Know Your Rights: Don't Be Bullied

If your bank or a payment app is treating you like a criminal for their technical failure, remember:

  • You have the Right to Redressal: A "technical glitch" is a Deficiency in Service under the Consumer Protection Act, 2019.

  • You have the Right to Compensation: You aren't just owed your money back; you are owed for the stress and time lost.

  • You have the Right to Fair Reporting: Incorrect CIBIL reporting is a violation of the Credit Information Companies Act.

How PRAN Foundation Can Help

PRAN (Policy Research Action Network) is more than a foundation; we are your shield against institutional high-handedness. We don't just write letters; we build legal cases that force regulators to take notice.

Are you trapped in a digital payment nightmare?

Don't wait for the recovery agents to call. Don't let your CIBIL score die.


Share This Article

Help us reach the millions of Indians currently struggling with "Ghost Payments." Every share puts pressure on regulators to close these gaps.

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