Rajesh Dhuddu
Partner and Emerging Tech Leader, PwC India

Rajesh Dhuddu is a prominent figure in the field of Emerging Technologies, particularly known for his work in Blockchain, Metaverse, AI and Cybersecurity.

He currently leads Emerging Tech Practice at PwC and a member of the leadership team at iDAC (Intelligent Data, Analytics and Cloud) responsible for shaping the thought leadership & Go To The Market initiatives in these technologies.

Prior to joining PwC, he was SVP and Global Head of Emerging Tech Practice at Tech Mahindra. In that role, he was responsible for leading initiatives in blockchain technology, web 3.0, cybersecurity cognitive tech & metaverse, focusing on creating business use cases and ecosystems around these technologies.

Before joining Tech Mahindra, Rajesh founded a payment processing company at Quatrro (promoted by Serial Entrepreneur Raman Roy) that integrated with major financial networks like Mastercard, Visa & NPCI. This venture marked the beginning of his deep involvement in the fintech and blockchain space.

Dhuddu has been recognized globally for his contributions to Emerging Technology. He is listed among the top 100 blockchain influencers by Lattice80 and has been part of the World Economic Forum’s Expert Network on both cybersecurity and blockchain . He has been awarded CXO Innovator of the Year, Most Inspiring Web 3 leader, Top 200 Technology Leaders in Asia and featured 3 times in a row in Forbes Blockchain 50 companies.

Additionally, he played a significant role in industry groups and educational initiatives, such as the Blockchain Special Interest Group at Nasscom and advisory roles at institutions like IIM Ahmedabad.

Overall, Rajesh Dhuddu’s work focuses on leveraging emerging technologies to drive digital transformation and solve real-world problems across various industries .

Pramod Mishra
Tokenization and Programmable Money lead Director, PwC India

Pramod Mishra is a Director at PwC India and leads Tokenisation and Programmable Money initiatives within the Emerging Technologies practice. He is one of the country’s leading practitioners in trusted digital infrastructure, blockchain, digital assets, Digital Public Infrastructure (DPI), and emerging technologies.

Over the past 16 years, he has worked at the intersection of technology, policy, and institutional transformation, helping governments, regulators, financial institutions, and global enterprises design systems that enable trusted, transparent, and resilient exchange of value.

In 2017, he co-founded and established PwC India’s blockchain lab, leading its evolution into one of the firm’s flagship cross-sector innovation practices. His work spans multiple jurisdictions, including India, the United Kingdom, Europe, the Middle East, Japan, Australia, and North America, where he has contributed to initiatives in digital assets, tokenisation, central bank digital currencies (CBDCs), regulated settlement networks, digital identity, sustainability, and public digital infrastructure.

Pramod has played a key role in architecting blockchain-enabled initiatives for India’s carbon market, designing digital asset and custody solutions for global financial institutions, establishing a Digital Asset Centre of Excellence for a leading UK bank, and delivering first-of-their-kind solutions across financial services, sustainability, supply chains, trade finance, citizen services, healthcare, digital provenance, and public sector transformation. His work has consistently focused on translating emerging technologies into scalable, trusted, and measurable outcomes.

His perspective has been shaped by working across diverse sectors, institutions, and cultures, reinforcing a simple belief: technology alone does not transform systems — trust does. He believes the next decade of innovation will be defined by the convergence of Digital Public Infrastructure, digital assets, AI, and programmable financial systems, enabling economies that are more transparent, resilient, and inclusive.

A frequent speaker, advisor, and contributor to national and global initiatives, Pramod is passionate about architecting technologies that create lasting public value. His philosophy is captured in a principle that continues to guide his work: “Trust cannot be claimed. It must be architected.”

Arjun T Ananth
Associate Director - Emerging Tech, PwC India

Arjun comes with over a decade of experience working in various sectors in the startup space including sports management, peripheral education and public funding. He has been involved in the Web3 ecosystem, over the last 6 years. His experience is primarily in Business Development, Account Management, Sales Strategy and Operations.

Currently Arjun works as an Associate Director in the Emerging Tech team at PwC, responsible for GTM, BD, Ecosystem & Partnerships.

Prior to joining PwC, Arjun was the Head of BD & Marketing at RocketX Exchange, driving the B2B business for the company. He was successful in strategizing the GTM plan for the new products launched for the B2B business. He successfully onboarded major blockchains such as Ava Labs, Polygon, Sui Protocol and others, and other Web3 projects such as Buk.com, Liminal, CoinDCX and many more to the RocketX platform.

Arjun also comes with expertise in evaluating and helping startups access grants and funding from the European Union and from private investors in the European market.

Arjun holds a PGDM degree from the Indian School of Business (ISB), Hyderabad and is a Computer Applications Graduate from Bangalore University. He actively contributes and participates in the Blockchain and AI, Tech and Consulting SIG’s at ISB.

Blockchain and Digital Assets in India

Blockchain and digital assets have moved from a peripheral innovation theme to a core policy and market-infrastructure agenda for central banks, regulators and financial institutions. By the end of 2025, stablecoins had reached a market capitalization of roughly USD 305.4 billion, underscoring why they now feature in mainstream financial-stability discussions. Tokenized real-world assets are projected to reach USD 30 trillion by 2034. Nearly every major central bank is in advanced stages of designing or piloting a Central Bank Digital Currency (CBDC). Against this backdrop, India occupies a position that is both remarkable and unresolved.

Chainalysis ranked India first in its 2025 Global Crypto Adoption Index, signalling that grassroots usage remains significant even under a restrictive domestic policy stance . The Indian crypto market is valued at USD 3.98 billion in 2025 and projected to reach USD 15 billion by 2035. India’s Web3 developer community is already the second largest globally, comprising approximately 11.8% of all crypto developers worldwide, and is expected to become the largest by 2028. More than 1,000 Web3 startups are active across the country. Global equity markets are USD 100 trillion, bonds USD 120 trillion, and real estate approximately USD 300 trillion – tokenizing even a fraction of these markets represents an opportunity that India cannot afford to cede to competing jurisdictions.

Yet India entered 2026 without a dedicated, comprehensive digital-asset statute; instead, the current perimeter is assembled through tax, AML and reporting rules rather than a single market-conduct framework. The regulatory architecture remains contested, with the Reserve Bank of India (RBI), the Securities and Exchange Board of India (SEBI), and the Finance Ministry yet to converge on a unified framework. The country’s extraordinary technology base and user adoption are running ahead of the governance structures required to channel them productively. This chapter examines India’s digital asset landscape across three dimensions – technology and infrastructure, regulatory architecture, and risk management – and assesses what the next phase must look like.

The Digital Rupee: From Pilot to Programmable Finance

India’s most consequential public-sector digital-asset initiative is the Reserve Bank of India’s Central Bank Digital Currency, the e₹. Launched in November 2022 for wholesale markets and December 2022 for retail, the e₹ has progressed with the methodical rigor one would expect of a sovereign monetary experiment. The e₹ pilot has scaled steadily since its 2022 launch. As at end-March 2025, the retail pilot covered 17 banks and 60 lakh users; by November 2025, government materials reported 82 lakh users and 11 lakh merchants, and the RBI’s April 2026 FAQ states that 19 banks currently offer e₹ wallets. What differentiates the Indian e₹ pilot is the RBI’s explicit focus on programmability: funds can be conditioned by parameters such as expiry date, geo-location, merchant category and designated counterparty. The e₹ is not being designed merely as a digital version of the Rupee, it is being engineered as a platform for purpose-driven, condition-bound, smart-contract-enabled money. Publicly available RBI material confirms that programmability is being explored across DBT schemes, interest-subvention schemes, lending and purpose-bound allowances. If you wish to retain state-level examples, they should be individually sourced; otherwise, use the verified Digital Food Currency pilot announced in February 2026 as the concrete illustration. These are not pilots in the academic sense – they are live, operational deployments of programmable sovereign money at scale. India may become the first large economy to operationalize programmable public finance at population scale.

On the wholesale side, the October 2025 launch of deposit tokenization via the Unified Markets Interface (UMI) marks a qualitative leap. The UMI is the RBI’s next-generation financial market infrastructure – a platform to tokenize financial assets including certificates of deposit (CDs), government securities and eventually bonds, with settlement occurring in wholesale CBDC. Early results from the inaugural CD issuance pilot, as noted by RBI Governor Sanjay Malhotra at the Global Fintech Fest 2025, demonstrate measurable improvements in settlement efficiency and counterparty risk reduction. Cross-border dimensions are also material, but the chapter should distinguish between them carefully: Project Nexus is a BIS-led initiative to connect domestic instant payment systems, not a CBDC pilot, while any separate CBDC-linked bilateral experiments should be explicitly sourced or omitted.

Tokenization: Building the Institutional Stack

Beyond the CBDC, India’s tokenization landscape is beginning to acquire institutional depth. In financial markets, the Indian Banks’ Digital Infrastructure Company (IBDIC) has deployed a live, production-grade blockchain platform that tokenizes MSME supplier invoices, enabling participating banks to extend affordable supply chain credit. This platform exited the RBI’s regulatory sandbox in 2025 and is now operational — a landmark that demonstrates India’s capacity to move from proof-of-concept to production in blockchain-enabled finance.

Market infrastructure players are actively exploring DLT-based issuance and settlement. The National Stock Exchange (NSE), National Securities Depository Limited (NSDL), Central Depository Services Limited (CDSL), Clearing Corporation of India Limited (CCIL), and IBDIC are each evaluating distributed ledger approaches to securities issuance, settlement and collateral management. The International Financial Services Centres Authority (IFSCA) at GIFT City, India’s international financial hub, is advancing tokenization through its regulatory sandbox and as a member of the Global Financial Innovation Network (GFIN), with real estate tokenization and digital securities issuance as priority areas. The National Payments Corporation of India (NPCI) is assessing programmable money and DLT integration with UPI and existing payment rails.

In non-financial markets, the ambitions are even larger. The Maharashtra government has announced plans to tokenise up to ₹50 trillion in dormant real estate assets, a programme that would, if implemented successfully it could redefine how emerging economies unlock dormant public and private assets through blockchain based ,asset tokenization . India’s carbon market, established under the Energy Conservation (Amendment) Bill 2022 following COP26 commitments, is being actively shaped by the Bureau of Energy Efficiency, the Ministry of Power, NTPC, and the Power Exchange India Limited (PXIL) as a framework suited to blockchain-enabled tokenization of carbon credits. India’s asset tokenization market is estimated at USD 122 million in 2025 and projected to reach USD 222 million by 2032 at an 8.9% CAGR, though these figures likely understate the medium-term scale given the Maharashtra programme alone.

Undergirding all of this is India’s extraordinary Digital Public Infrastructure (DPI) stack: Aadhaar for identity, UPI for payments (processing 20 billion transactions and ₹25 trillion monthly as of August 2025), Digi Locker for document management, and the Account Aggregator framework for data portability. This DPI layer provides a compliance-grade, scalable foundation for tokenization that few other jurisdictions can match. Card tokenization has already reached 910 million tokens created by December 2024, with over 3.2 billion transactions processed since launch – a demonstration of India’s capacity to execute token-based financial infrastructure at population scale.

The broader resilience of India’s financial system provides an important foundation for future tokenized market infrastructure. The RBI’s June 2026 Financial Stability Report highlights strong capitalisation, improving asset quality and robust liquidity across banks and non-bank financial institutions, reinforcing the conditions necessary for the safe adoption of emerging digital asset and tokenization models.

REGULATORY ARCHITECTURE: STRUCTURED AMBIGUITY

The Current Perimeter

India’s regulatory framework for digital assets is best described as structured ambiguity – a set of targeted interventions through tax, anti-money laundering, and reporting frameworks that define compliance obligations without providing the comprehensive legal clarity that markets require. Unlike the EU’s Markets in Crypto-Assets Regulation (MiCAR), which became fully applicable in December 2024, or Singapore’s Payment Services Act which provides a licensing framework for digital payment tokens, India has not enacted dedicated digital asset legislation.

Three pillars define the current perimeter. First, classification: crypto assets and NFTs are classified as Virtual Digital Assets (VDAs) under Section 2(47A) of the Income Tax Act 1961, as introduced by the Finance Act 2022, with the Finance Bill 2025 expanding this definition to include all crypto-assets broadly, effective April 2026. Second, AML and countering the financing of terrorism (CFT): under the Prevention of Money Laundering Act 2002, VDA service providers are designated as Reporting Entities subject to FIU-IND oversight. As of 2025, 49 VASPs are registered, with cumulative penalties of approximately INR 28 crore issued for non-compliance. India has also implemented FATF Recommendation 16 (the Travel Rule), requiring VASPs to collect and transmit originator and beneficiary information on transactions. Third, tax and reporting: a 30% flat tax on VDA gains with no loss set-off or carry-forward, a 1% tax deducted at source on transfers exceeding INR 10,000, and from April 2026, mandatory crypto transaction reporting under the new Section 285BAA with penalties of INR 200 per day for late filing and INR 50,000 for incorrect reporting.

Global regulatory priorities continue to evolve toward implementation and supervision of digital asset frameworks. The RBI’s June 2026 Financial Stability Report notes that international standard-setting bodies have advanced work on digital assets as part of broader financial stability and resilience initiatives, reflecting the continued mainstreaming of digital assets within regulatory agendas worldwide.

The Regulatory Impasse and the Path Forward

The defining challenge of India’s regulatory moment is the impasse between the Finance Ministry and the RBI. SEBI has proposed a multi-regulatory framework in which it serves as the primary supervisor for crypto exchanges, with the RBI retaining jurisdiction over cross-border transactions, foreign exchange implications and monetary dimensions. The Finance Ministry has been engaged in preparatory consultations ahead of Union Budget 2026-27. The RBI, however, remains institutionally opposed to comprehensive crypto regulation, on the grounds that doing so confers undue legitimacy on private crypto assets. A government document reported by Reuters in September 2025 reflected this view, noting that Indian investors held approximately USD 4.5 billion in digital assets but that this level of exposure did not yet pose systemic risks.

The consequences of this impasse are visible and measurable. A long-awaited discussion paper from the Department of Economic Affairs (DEA) on crypto regulation – promised publicly at least five times between 2024 and early 2026 – remains unpublished as of April 2026. The Supreme Court has expressed dissatisfaction with the regulatory vacuum, warning that the absence of legislation has enabled financial misconduct and flows resembling hawala. The Delhi High Court, in January 2025, sought formal responses from the RBI, SEBI and the Ministry of Finance on VDA regulation following a public interest petition – a signal that judicial pressure on the executive is mounting.

India is not alone in navigating this complexity, but it is increasingly an outlier in failing to resolve it. The PwC and Citi ‘Digital Dollars’ report (2025) characterizes stablecoins as experiencing a ‘ChatGPT moment’ – a point at which the technology crosses from niche interest to board-level strategic agenda. The report notes that the capital markets use case – stablecoins as settlement instruments – holds significant, largely unexplored potential. For India, with its massive remittance flows, its UPI-anchored payments ecosystem, and its stated INR internationalization ambitions, the strategic case for a clearly articulated stablecoin policy is not merely compelling – it is urgent.

The Economic Survey 2025-26 hinted at regulatory backing for stablecoins. Commerce Minister Piyush Goyal publicly noted in 2025 that India would introduce a digital currency “somewhat like the stablecoins the USA has announced”. Finance Minister Nirmala Sitharaman has acknowledged that stablecoins are rapidly transforming global finance. These signals suggest political will exists at the executive level; what remains missing is regulatory alignment. India is among 52 countries adopting the OECD’s Crypto- Asset Reporting Framework (CARF) by 2027, which will substantially expand data-sharing and compliance obligations regardless of whether domestic legislation is enacted. International pressure, if not domestic political will, may ultimately force resolution.

RISK MANAGEMENT: NAVIGATING INDIA’S SPECIFIC EXPOSURES

Cybersecurity and Custody Risk

The most visceral risk event in India’s digital asset history occurred in July 2024, when WazirX – one of the country’s largest cryptocurrency exchanges by trading volume – suffered a cyberattack resulting in losses exceeding USD 200 million, the largest exchange breach in Indian history. The attacker exploited vulnerabilities in WazirX’s multi-signature wallet infrastructure, draining assets across multiple token classes. The episode exposed a structural gap that characterizes much of India’s digital asset market: exchanges operating without mandatory cybersecurity standards, cold storage requirements, client asset segregation rules, or insurance mechanisms of any kind.

The aftermath was as instructive as the breach itself. WazirX, incorporated in Singapore, proposed a restructuring plan before Singapore courts – a plan that Indian investors challenged through domestic litigation, creating a multi-jurisdictional enforcement tangle that remains unresolved. The RBI, when asked by the Delhi High Court for its position on VDA regulation in the context of this and similar risks, declined to assert regulatory authority over VDA platforms. The court’s observation that this was “unfortunate” given the systemic risk exposure is a fair assessment.

For institutional players entering or considering India exposure, the WazirX case functions as a definitive data point on operational risk in an unregulated custody environment. The risk management implication is clear: until India enacts mandatory custodial standards – encompassing cold storage minimums, proof-of-reserve obligations, client asset ring-fencing, and insurance requirements – institutional exposure should be routed through regulated entities with explicit custody frameworks, such as those operating under IFSCA’s GIFT City framework.

The increasing digitisation of financial services is expanding cybersecurity vulnerabilities across the financial system. RBI’s June 2026 Financial Stability Report identifies cyber risk as an emerging source of financial instability, with AI-enabled cyberattacks and third-party technology dependencies presenting significant concerns for regulated institutions. As digital asset ecosystems become more interconnected and infrastructure-intensive, operational resilience, cyber controls, and technology governance are likely to become critical pillars of institutional digital asset adoption.

Market and Systemic Risk

India’s punitive tax framework has materially reshaped its domestic digital asset market – and not entirely in the direction regulators intended. The 30% flat tax rate and 1% TDS introduced in 2022 reduced on-exchange trading volumes dramatically, with monthly volumes stabilizing at USD 1.5 to 2 billion, a fraction of pre-tax highs. The unintended consequence is that significant activity has migrated to offshore exchanges, peer-to-peer platforms, and OTC channels that are less visible to domestic regulators and more exposed to manipulation, fraud, and money laundering. The Income Tax Department’s issuance of over 44,000 tax notices to individuals in 2025 for unreported VDA transactions is evidence that the migration is occurring at scale.

The prohibition on SEBI-regulated funds from digital asset exposure creates a parallel systemic risk: it prevents the development of an institutional-grade, regulated investment market in India, while India’s retail investors remain exposed to unregulated exchange risk. The absence of regulated custody, fund structures, and market-making in digital assets means that Indian markets lack the liquidity depth, price discovery mechanisms, and investor protection infrastructure that comparable jurisdictions – Singapore, Hong Kong, the UAE – are actively building.

Legal and Operational Risk

India’s legal system has not yet produced authoritative guidance on several questions that are foundational to institutional digital asset activity. The enforceability of smart contracts under the Indian Contract Act 1872 has not been tested before a superior court. The treatment of tokenized securities under the Securities Contracts (Regulation) Act and SEBI regulations is unresolved. The legal character of a tokenized real estate title under the Transfer of Property Act or the Registration Act is uncertain. For enterprises deploying blockchain in supply chain, trade finance, or treasury applications, this legal uncertainty translates directly into unquantifiable contract risk and limits the scale of deployment that risk-averse institutions are willing to authorize.

Cross-jurisdictional operational risk is also elevated, as the WazirX case demonstrates. India’s AML framework applies extraterritorially in principle – FIU-IND has issued notices to offshore exchanges serving Indian residents – but enforcement against entities without Indian registration remains practically limited. Compliance officers at multinational banks with Indian operations should treat India’s digital asset regulatory environment as a ‘watch and prepare’ jurisdiction: building internal frameworks now in anticipation of a regulatory inflection point that appears increasingly imminent.

PWC INDIA’S PERSPECTIVE

Blockchain and digital assets in India are transitioning from a phase of experimentation to becoming a foundational element of the country’s next-generation financial infrastructure. As tokenization gains momentum globally – driven by increasing institutional participation, evolving market infrastructure, and the digitization of real-world assets – India is uniquely positioned to participate in and shape this transformation. The country’s success in building population-scale digital platforms has created a strong foundation for extending innovation beyond digital payments to programmable money, tokenized assets, and new models of value exchange.

A key differentiator in India’s journey is the strength of its Digital Public Infrastructure (DPI) ecosystem, which provides trusted digital identity, real-time payments, and secure data-sharing capabilities at unprecedented scale. These foundational layers create the conditions for an interoperable and sovereign digital asset ecosystem where tokenized instruments, programmable financial products, and regulated settlement mechanisms can coexist seamlessly. Emerging initiatives such as NPCI’s open-source Drunix framework further reinforce this direction by enabling scalable distributed ledger infrastructure aligned with India’s public-digital-infrastructure philosophy. Together, these developments have the potential to accelerate the adoption of production-grade tokenization use cases across the financial sector.

Looking ahead, the realization of this opportunity will depend on the continued alignment of technology innovation, regulatory clarity, governance frameworks, and risk management practices. Institutions that can successfully navigate these dimensions while leveraging India’s digital foundations will be best positioned to unlock value from blockchain and digital assets, helping drive a more efficient, inclusive, and resilient financial ecosystem.

PWC INDIA – EMERGING TECHNOLOGY PRACTICE

PwC India’s Emerging Technology practice within the Cloud Engineering and Data Analytics (CEDA) division clients on blockchain, digital assets and adjacent technologies through work spanning strategy, operating-model design, compliance transformation, tokenization readiness and implementation support. In the India context, the most relevant capabilities are CBDC readiness, digital-asset governance, control design, regulatory-operating-model alignment and enterprise DLT deployment. Our multidisciplinary team brings together technology architects, regulatory strategists, risk advisors and deal specialists to help clients navigate the digital asset landscape – from enterprise DLT deployment and CBDC readiness to VDA compliance frameworks, tokenization strategy, and Digital Assets Centre of Excellence design and build. PwC has supported leading global financial institutions in designing 2030 digital asset strategies, building DA CoE capabilities, and deploying production-grade blockchain infrastructure for trade finance, FX liquidity management, and cross-border settlement.