Over the past decade India's vibrant payment ecosystem has
grown by leaps and bounds. The surge of online platforms
(e-commerce, OTT, etc.) coupled with ‘hassle-free'
payment channels (i.e., digital wallets, UPI, credit cards, etc.)
has pushed the Indian user to transition to online payments in
everyday life.
For the first half of the last decade, the Reserve Bank of India
(“RBI”) was largely a silent
spectator, monitoring the growth yet not strictly tethering
innovations and practices adopted in this space. As the volume of
digital transactions kept increasing, however, so did the level of
fraud and illegal behaviour. Consequently, the RBI has in recent
years sought to implement changes to curb payment fraud, including
introducing payment data localisation, prescribing norms for
undertaking recurring payments on online platforms, guidelines to
regulate payment aggregators and payment gateways, etc. These
changes denote the RBI's intent on regulating
