RM Compliance
llms.txt
Playbook/Playbook08

Open questions, counsel items, and the verify list

Markdown

This is the honest list of what is not settled. Items move off this page only when a human closes them with a decision and a date.

Counsel and adviser decisions needed#

# Question Affects Safe default meanwhile
1 Appoint a UK Article 27 representative and an EU representative; confirm ICO fee registration Scribe, AIBookly, any UK or EU user Disclose Indian storage and transfer tools; keep UK and EU marketing passive
2 UK VAT registration (no threshold for B2C digital services) and EU OSS; US sales-tax nexus monitoring Scribe, AIBookly, Digitailor, Nimitra, Rollout Use Stripe Tax for calculation; track sales by country and state from day one; B2B with VAT numbers only until registered
3 GST treatment of each export line under LUT; Softex and EDPMS applicability for SaaS subscriptions; FIRC handling RM Bills, every foreign sale Zero-rate exports under LUT with FIRC filed; CA review quarterly
4 Per-school payment aggregator structure (Razorpay Route vs per-school merchant accounts) Tulip No fee collection until settled
5 RM Music: licensing path or permanent private status RM Music Private household use only
6 Medical-device classification and evaluation plan for the RM Pharma reader and DuoFlow RM Pharma, DuoFlow Investigational labelling; no clinical claims
7 Google restricted-scope verification and CASA for Gmail access Digitailor, Folio (Calendar) Forwarding-address design or postpone inbox access
8 Attorney review of CoParent, Tulip, isdwell, Nimitra, Scribe, Dwell legal drafts All Drafts stay marked "draft, under review"
9 Immigration-authorship guidance for AI-assisted books used in petitions AIBookly, Merit Document human authorship; disclose AI assistance to counsel
10 Online Safety Act scoping: which RM services have UK links and are user-to-user Nest, Meet, Drive, Music, MyJanata, Rollout Complete an illegal-content risk assessment template for Nest and Meet
11 Trademark search and filing for product names (Meet, Drive, Nest, Planet, Atlas, Tulip, Folio, Rollout, Nimitra, Scribe, Digitailor, isdwell, Dwell) All House mark always present; no third-party trade dress
12 DMCA agent registration with the US Copyright Office Drive, Nest, MyJanata, Rollout Takedown page and mailbox live anyway
13 Data Protection Officer or contact person appointment and publication All (DPDP) Grievance page with a named person
14 SEBI posture if Lakshmi is ever shown outside the company Lakshmi Internal only
15 Dietitian or nutrition-advice licensing in target US states for individualised plans RM Health Educational suggestions; coach title only
16 Commercial-use terms of the ISP line and insurance (cyber, general liability) for hosting clients RM Cloud Disclose nothing beyond what is true; get quotes
17 Colorado AI Act and California ADMT applicability review for Dwell, LegalOS, Merit, RM Health Those apps Human-decides design, notices, impact assessment drafts
18 Company annual calendar: ROC filings, GST returns, TDS, professional tax, Shops and Establishments (AP), statutory audit, board meetings, DPIIT and Udyam registrations Company CA and CS engaged; calendar in RM Home
  • Rotate and purge: Calendar/Folio server/.env (Google client secret, SECRET_KEY, mail password), Meet historical secrets (rotated, flags pending), CoParent shared SECRET_KEY (three-key split), LegalOS documented passwords, any key that appears in memory notes.
  • Scribe has no Postgres backups; Meet keeps state in process memory; RM Health runs on SQLite with one worker.
  • Meet: E2EE claim, host authorisation, serve.cjs traversal, dev guest endpoint in production.
  • CoParent: E2EE claim, 65B wording, attorney-access model.
  • Tulip: global Razorpay key for school fees.
  • Digitailor: channel-terms review and bot-detection response policy.
  • Authenticator: 2.5 GB untracked tree; bring it under version control without secrets.

Verify list (law that may have moved after 2026-08-21)#

Item Why it matters Check
DPDP Rules commencement dates and the exact breach-report timeline and rights-response period Every app MeitY notifications
IT Rules synthetic-media labelling amendment final text Any generated media MeitY
FTC click-to-cancel status after the 2025 vacatur; any new rulemaking Subscriptions FTC
Colorado AI Act effective date (30 June 2026) and any amendments Dwell, LegalOS, Merit, RM Health Colorado legislature
EU AI Act Annex III high-risk timeline (Digital Omnibus delay proposal) EU users EUR-Lex
California CPPA ADMT and risk-assessment regulations phase-in US users CPPA
UK DMCC subscription-contract provisions commencement UK subscriptions CMA, DBT
UK PECR analytics-cookie exemption scope after the Data (Use and Access) Act 2025 UK cookie layer ICO
Apple and Google external-purchase-link rules by market In-app subscriptions App Store and Play policy pages
GST e-invoicing threshold; UK VAT and EU OSS rules for non-resident digital suppliers Billing CBIC, HMRC, EU
RBI recurring-payment limits and e-mandate rules; PA Directions 2025 Indian billing, Tulip RBI
CERT-In Directions amendments Logging and reporting CERT-In
TRAI consent-registration (DCA) rollout for commercial messaging SMS and WhatsApp TRAI
Medical Devices Rules software classification guidance RM Pharma, DuoFlow CDSCO
COPPA amended rule compliance date (April 2026) Any US minors FTC
State privacy laws adding or lowering thresholds (Texas, Nebraska, Maryland, and new states) US users State AGs
Online Safety Act codes and Ofcom guidance updates UK U2U services Ofcom

Review cadence#

  • Quarterly: verify list, vendor register, access review, open counsel items.
  • On every new app or new data class: app register entry before first user.
  • Twice a year: incident drill, restore drill, copy audit for banned claims.
  • Yearly: full playbook review with counsel; update REVIEWED.