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ARTICLE · 11 JUNE 2026

E-Mandate Framework | Digital Payments

Khaitan & Co.
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India’s digital payments landscape / ecosystem has grown exponentially and at a pace that regulators struggled to match. The rules governing automatic recurring charges remained scattered across multiple directives issued at different times.

IndiaCriminal Law
Nikhilesh Panchal
Nikhilesh Panchal
Amiya Kumar Pati
Amiya Kumar Pati
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Introduction

India’s digital payments landscape / ecosystem has grown exponentially and at a pace that regulators struggled to match. The rules governing automatic recurring charges remained scattered across multiple directives issued at different times. Between 2019 and 2024, 8 separate circulars attempted to regulate e-mandates; each adding layers, refining thresholds, or extending rules to new payment instruments.

Regulatory Chronology (2019–2026)

  • 2019: Initial enablement of card‑based recurring e‑mandates introduced the basic auto‑debit construct and issuer responsibilities, with an emphasis on Additional Factor of Authentication (AFA) at registration and consumer control. In 2020, the scope expanded to Unified Payments Interface (UPI) and Prepaid Payment Instruments (PPI) as recurring use‑cases matured.

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