Context:
- There is the need to examine the proposed change to Section 10A of the Payment and Settlement Systems Act, through the Taxation Laws (Amendment) Bill, 2026.
- The amendment replaces the existing prohibition on charges for BHIM-UPI and RuPay with an enabling provision under which the government may notify modes of payment on which charges can be imposed.
- While no charge has been introduced yet, opening this door could undermine the foundational principle of free and universal digital payments.
UPI - From Payment Innovation to Public Digital Infrastructure:
- When Unified Payments Interface (UPI) was introduced (by NPCI), the objective was to reduce dependence on cash by providing a simple, interoperable and low-cost payment system.
- UPI has since become the backbone of India's digital payments ecosystem. For example, it processed over 24,000 crore transactions in 2025-26, roughly 66 crore transactions a day, worth about ₹314 lakh crore.
- It accounted for around 85% of India's digital retail payments and nearly half of the world's real-time payments.
- A large proportion of transactions are small-value payments—around ₹1,300 on average, with 86% of merchant payments below ₹500.
- These include everyday payments to vegetable vendors, autorickshaw drivers, small shops and street businesses.
- Thus, UPI's significance lies not merely in transaction volumes but in its ability to formalise small-value economic activity and make digital payments accessible to ordinary citizens.
Why MDR is the Wrong Pricing Model?
- Merchant Discount Rate (MDR) originated in the card-payment ecosystem, where multiple intermediaries—issuer, acquirer and payment network—share costs and assume risks associated with physical infrastructure and credit.
- UPI operates differently:
- It is based on interoperability, rather than closed payment networks.
- Transactions move directly between bank accounts.
- There is no physical card or terminal.
- There is no comparable credit-default risk.
- Settlement is almost instantaneous.
- UPI is built on an open protocol and common infrastructure.
- Therefore, applying the traditional MDR model to UPI would amount to imposing an inappropriate legacy pricing mechanism on a fundamentally different digital public infrastructure.
The Cost of Zero-MDR UPI:
- Banks and payment providers nevertheless incur real costs in operating UPI. The government has attempted to bridge this gap through incentives.
- However, the projected expenditure on these incentives has increased sharply—from about ₹3,631 crore to nearly ₹4,373 crore.
- The solution should not be to recover these costs directly from merchants and consumers through MDR.
Alternative - Fund UPI Through the Savings it Creates:
- The state and financial system derive substantial savings from digitisation:
- The RBI spends ₹5,000–6,400 crore annually merely on printing currency.
- Digital payments reduce the costs of cash printing, storage, transportation and handling.
- Banks benefit from the lower-cost digital transaction ecosystem and the ability to retain deposits and lend them.
- Digitalisation reduces transaction costs across the economy.
- Hence, if UPI generates savings for the government and banks, a portion of these savings can finance the infrastructure that generates them.
Why MDR Could Become Self-Defeating?
- India's digital-payment transition remains price-sensitive. Even a small MDR can make digital transactions less attractive than cash.
- For example, a merchant charged 2% may pass the cost to customers as a “digital payment charge” or discourage digital payments altogether.
- Even a 0.3% charge could significantly affect merchants operating on thin margins.
- The result could be a reversal of India's cash-to-digital transition, particularly among small merchants.
Protecting UPI as a Public Good:
- UPI has succeeded because it is free, instant, interoperable, universal, and accessible.
- Its expansion has brought millions of people and small businesses into the formal digital economy.
- Therefore, UPI should not be treated simply as a commercial payment product. It is a form of digital public infrastructure, and its benefits extend beyond individual transactions.
Way Forward:
- Instead of imposing MDR:
- Fund UPI through savings generated by reduced cash dependence.
- Develop transparent, formula-based support for payment infrastructure.
- Ensure that any support is linked to value delivered, rather than transaction pricing.
- Preserve affordability for small merchants and consumers.
- Avoid policies that could encourage a return to cash.
- The debate illustrates the broader challenge of balancing financial sustainability with inclusive digital public infrastructure.
- India's UPI model demonstrates how interoperability, network effects and state-supported digital infrastructure can reduce transaction costs while promoting financial inclusion.
Conclusion:
- The central proposition is clear: UPI should remain free at the point of use.
- If digitalisation saves money for the government and banks, those savings should help finance UPI rather than recovering costs through MDR from merchants and consumers.
- Preserving zero-cost UPI is therefore presented not merely as a payment-policy choice, but as a means of protecting India's cash-light, inclusive and digitally enabled economy.