Table of Contents
Via the Payments Digest, we aim to provide a view on key developments with payments regulations each month. In the last section we also share our internal data on beneficiary bank downtimes for the last month.
PART I: RBI extends Tokenisation deadline to June 30th 2022
Quick Take: The extended deadline allows time to identify and resolve issues with the industry-wide implementation of CoFT and educate consumers, before deletion of card data by June 30th.
The RBI mandate for deleting card data which was to come into force by December 2021 has been extended until June 30th 2022, allowing more time for various industry stakeholders to implement Card-on-File Tokenisation or (CoFT). Apart from CoFT, industry stakeholders have also been asked to devise alternate mechanisms for handling other use-cases (like recurring payments, EMIs, etc) or post-transaction activities (such as chargebacks, dispute resolution, reward/loyalty programs, etc.) that currently involves CoFT data.
The extension is a welcome step for (i) allowing resolution of issues that emerge with implementation at an ecosystem-level and, (ii) allowing time for consumers to be educated about the meaning and implications of CoFT. Its benefits are outlined below:
Key Takeaways
| For Merchants | For the Payments Industry | For Consumers |
| For merchants, there are changes involved for implementing the new norms, such as becoming or integrating with a token requestor. The new deadline provides more time for this, which may involve new integrations, while enabling smoother migration of the existing saved customer card data to the tokenised form prior to the June 30th deadline. Post the deadline all saved card data will need to be deleted. Thereafter, customers will need to re-enter card data to make card payments. | For the remaining payments industry, work has been ongoing since the permission for CoFT in September to rework card payment and other related processes, now that no one apart from card networks and issuing banks can store actual card data. Solutions found, for eg., include relying on transaction IDs for refunds, introducing token-BIN mapping for BIN based offers, etc. With the extended deadline, this allows time to identify and resolve issues as they emerge with CoFT’s implementation at an industry-wide level. | For consumers, there will be no change in the card payment process, barring the one-time activity of generating the card token by giving consent (say in the form of ‘save my card’ style checkbox at checkout’. Token and cryptogram generation moreover is real-time, thus allowing transactions speed and volume to continue unimpacted. The extended timeline mainly brings the benefit of allowing more time for smoothly converting their existing saved cards to tokens- minimizing disruption for them as industry-wide implementation issues are identified and resolved. |
(Related Read: Payments Digest by Cashfree- September 2021- Permitting card on file tokenisation)
PART II: UPI updates: Wallets, enhanced limits, feature phones, etc.
Quick Take: Multiple steps from proposing a UPI ’wallet’ for easing low value transactions and enhancing UPI limits to ₹5L for IPO applications have been introduced.
The RBI and the NPCI have taken many key steps to enhance UPI (outlined in the table below). In addition, the RBI is proposing to issue a discussion paper on charges in payments systems, aiming to cover not only UPI but also various channels like credit cards, debit cards, PPIs, etc. The paper will also invite feedback on convenience fees, surcharges, how to make payments more affordable, etc.
| Steps | Details | Impact |
| Enhanced UPI Limits | The NPCI has enhanced UPI transaction limits from Rs. 2L to Rs.5L for investments in IPOs and in GSecs via the RBI Retail Direct Scheme. For RDS transactions, a separate purpose code of 25 has been issued. | The step brings support to investment via UPI. IPO applications in the Rs. 2-5L category apparently constitute approximately 10% of all subscription applications, as per the RBI. The step comes post an increase in IMPS transaction limits to Rs.5L in October. |
| Increased settlement cycles | The NPCI also introduced new settlement cycles UPI and IMPS (which forms the underlying rails for UPI) from 6 to 8 cycles for daily settlement. | The 24×7 availability of RTGS has driven an increase in IMPS settlement cycles, allowing an increase in UPI transaction volumes by reducing credit and settlement risks here. |
| Proposed UPI ‘wallet’ | The RBI proposed introducing an ‘on-device’ wallet for UPI for small-value transactions. | This aims to enable a simple process flow for small-value transactions, in turn helping conserve bank resources. From a user perspective, there will be no change in the transaction experience. |
| UPI on feature phones | The RBI also proposed a UPI based payments product for feature phones. | While details are yet to be revealed, this will be a useful feature with the aim of deepening financial penetration. The first cohort of the RBI sandbox for retail payments had seen similar solutions, that have since exited the sandbox. |
| Reconciliation for BHIM Bill payments | For UPI member banks, the NPCI also issued some pointers for reconciliation of BBPS bill payment transactions that are routed through the BHIM UPI application. | This promises to improve reconciliation here. The step was taken taking into account reconciliation related grievances that were raised with the NPCI. Currently, UPI member banks process reversals to customer accounts for declined, timed out (etc.) transactions on the basis of credit adjustment files generated by BHIM, for any transactions that are unsuccessful or not present at BBPS. Now, banks have also been asked to issue refunds by identifying cases where a successful debit to the customer’s account was made, but no claim was made in BBPS settlement. These are to be processed in T+3 days unless claims are raised within 2 days of the transaction date. |
PART III: Zero MDR: MeitY reimbursement scheme for RuPay and UPI introduced
Quick Take: Banks will receive govt. Incentives between 0.15- 0.40% per transaction for RuPay and UPI transactions, providing some respite post the withdrawal of MDR in 2019.
Zero MDR, introduced in Budget 2019, has been a pain point for many in the industry. The step waived MDR as a revenue source for banks and others on UPI and RuPay transactions, which was approximately 1% of transaction value. Every budget thereafter has been met with disappointed hopes from various corners for MDR to be reintroduced as a revenue source. Last year in 2021, the Budget instead earmarked a fund of Rs. 1500 crore to support digital payments adoption and growth (the latest 2022 Budget has announced that the support will continue this year as well).
The deployment of these funds has taken the form of a Meity incentive scheme, announced this December. Acquiring banks will be incentivised via payment of a percentage of the value of RuPay P2M and low-value BHIM-UPI P2M transactions (upto Rs.2000/-). The scheme will thus operate in addition to schemes like the Payments Infrastructure Development Fund which seeks to promote digital payments adoption through the subsidized deployment of PoS terminals in lower-tier centers in the country. The incentive will be as follows:
For RuPay Debit Card
| Merchant Category | Incentive rate per transaction |
| PoS and eCom transactions (other than Industry Programmes) | 0.40% capped at ₹ 100 |
| PoS and eCom transactions (Industry Programmes, i.e., Insurance, Mutual Fund, Government, Education, Railways, Agriculture, Fuel, Jewellery and Hospital. BHIM-UPI P2M Transactions) | 0.15% capped at ₹ 6 |
For BHIM-UPI P2M Transactions
| Merchant Category | Incentive rate per transaction |
| Other than Industry Programmes 0.25% | 0.25% |
| Industry Programmes, i.e., Insurance, Mutual fund, Government, Education, Railways, Agriculture, Debt Collections, Fuel, Petroleum products, POI Funding transaction, Telecommunication, Utility payments, Business/ Personal Services and Hospital. | 0.15% |
The estimated financial outlay for the scheme is ₹1,300 crore. Reimbursement of claims will be on a quarterly basis. The incentive moreover is to be shared by the acquiring banks with other stakeholders, as per the distribution share that has been devised by the NPCI. In the case of UPI, the NPCI has issued additional instructions, indicating that AutoPay, Mandate (IPO), Overdraft and eRUPI transactions are excluded from the ambit of this incentive.
Others:
- Payment Banks and Small Finance Banks as RBI Agency Banks: The RBI has announced that scheduled payments banks and small finance banks will be eligible to conduct government agency business, after the revised framework in May allowed this for scheduled private sector banks.
- LEI for Cross-border transactions: The RBI has introduced a Legal Entity Identifier for cross-border transactions. This is 20 digit no. used to uniquely identify parties to financial transactions worldwide. Earlier this year an LEI was also introduced for large value txns in NEFT/RTGS.
(Related Read: Payments Digest by Cashfree: Jan 2021)
- Joint Parliamentary Committee Report on the PDP Bill: The JPC report on the PDP Bill has finally been released, taking a step closer to the introduction of a privacy and data protection law. In addition to recommendations that impact the ecosystem as a whole, such as data localisation requirements, specific recommendations impacting the payments industry include a proposal for an Indian alternative to the SWIFT payment system to ensure privacy, along the lines of USA’s Ripple and EU’s INSTEX.
(Related Read: Payments Digest by Cashfree- November 2021- Regulating Digital Lending & Neobanks)
Cashfree Payments’ Data on Beneficiary Bank Downtimes
In this section we share our consolidated internal data on beneficiary bank downtimes for the month of November 2021- a part of our efforts to mitigate the impact of bank system outages and downtimes on payments. More details are here. For live updates on unscheduled beneficiary bank downtimes, please visit our Status Page here.
That’s all for this edition.
| This edition has been authored by Asheeta Regidi and assisted by Urmil Shah. |
Bibliography:
- Lok Sabha Secretariat: Joint Committee on the Personal Data Protection Bill, 2019, dated December 16, 2021
- MeitY Notification: Incentive scheme for promotion of RuPay Debit cards and low-value BHIM-UPI transactions (P2M), No. 24(1)/2020, dated December 17, 2021
- NPCI Circular: Introduction of additional settlement cycles for IMPS from 6 to 8, NPCI/IMPS/OC No. 108/2021-22, dated December 9, 2021
- NPCI Circular: Implementation of Rs. 5 lakh limit per transaction for specific categories in UPI, NPCI/UPI/OC No. 127/2021-22, dated December 9, 2021
- NPCI Circular: Reconciliation and handling of declined/timed out transactions in UPI for BBPS transactions routed through BHIM application, NPCI/UPI/OC No. 129/2021-22, dated December 15, 2021
- NPCI Circular: Submission of successful onus transaction data (not routed through NPCI) towards incentive scheme for promotion of low-value BHIM-UPI transaction (P2M), NPCI/UPI/OC No. 131/2021-22, dated December 23, 2021
- RBI Notification: Tokenisation – Card Transactions: Permitting Card-on-File Tokenisation (CoFT) Services, RBI/2021-22/96, dated September 07, 2021
- RBI Notification: Introduction of Legal Entity Identifier for Cross-border Transactions, RBI/2021-22/137, dated December 10, 2021
- RBI Notification: Government Agency Business Arrangement – Appointment of Scheduled Private Sector Banks as Agency Banks of Reserve Bank of India (RBI), RBI/2021-22/140, dated December 15, 2021
- RBI Notification: Restriction on storage of actual card data [i.e. Card-on-File (CoF)], RBI/2021-2022/142, dated December 23, 2021
- RBI Press Release: Statement on Developmental and Regulatory Policies, 2021-2022/1323, dated December 8, 2021
- Website: Unscheduled Bank Downtimes, Cashfree Payments
