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Showing posts with label RBI. Show all posts
Showing posts with label RBI. Show all posts

Wednesday, September 16, 2026

Citizen Observation 44 of 777 | UPI MDR | The ₹2,000 Free Slab Should Grow by ₹100 Every Year

  

Published 16th September 2026

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru

https://in.linkedin.com/in/prashantnayakanti

 

The Short Intro

At 8:30 in the morning, Ramesh stops at his neighbourhood kirana store in Bengaluru.

A little later, Asha picks up rice, dal, cooking oil, vegetables and milk from a supermarket in Mysuru. In Hyderabad, Meena pays for a similar basket of everyday essentials.

Different people. Different places. Different baskets.

But today, one number sits quietly underneath these everyday purchases:

₹2,000.

The new UPI MDR framework keeps P2M transactions up to ₹2,000 outside the standard MDR slab.

But should that number remain frozen while the price of the basket keeps moving?


The Trigger

On 15 September 2026, NPCI announced the UPI MDR framework under which a 0.40% MDR applies to Person-to-Merchant transactions above ₹2,000, while the standard MDR does not apply to transactions up to ₹2,000. The framework takes effect from 15 October 2026.

The intention is clear: protect everyday, small-value UPI payments.

But everyday life keeps changing.

The rice that Ramesh buys today will not necessarily cost the same next year.

The dal, cooking oil, vegetables and milk in Asha's basket will not necessarily remain at today's prices.

The basket changes.

So, instead of revisiting the MDR threshold every year, perhaps there is a simpler citizen-friendly approach:

₹2,000 today.
₹2,100 next year.
₹2,200 the year after.

A small, predictable ₹100 annual increase.

Can the ₹2,000 Free Slab grow by ₹100 every year?

Prospective Audience

Who would notice the difference?

Ramesh, buying the weekly groceries at a kirana store in Bengaluru.

Asha, paying for a household basket at a supermarket in Mysuru.

Meena, buying provisions for her family in Hyderabad.

Suresh, stopping at a neighbourhood store in Vijayawada.

And thousands of similar customers across India — not necessarily making one large purchase, but gradually seeing the same everyday basket become more expensive.

For them, the question is not about MDR mathematics.

It is much simpler:

Will the free UPI slab keep pace with the everyday basket?

The proposal is therefore aimed at the future value of the ₹2,000 threshold, rather than changing today's ₹2,000 threshold.

 

Act I — Today's Basket

Today, ₹2,000 is a clearly defined line.

A family buys its rice, dal, cooking oil, vegetables, milk and other essentials.

The basket reaches:

₹1,850 — within the free slab.

Add a few more essentials:

₹2,050 — now above the ₹2,000 line.

The basket has changed by only ₹200.

But the threshold has not moved.

 

Act II — The Same Basket, Another Year

Now move the calendar forward.

The same family.

The same kirana store.

The same rice.

The same dal.

The same cooking oil.

The same vegetables.

But prices have moved.

What was a ₹2,000 basket may gradually become a ₹2,100 basket.

Then perhaps ₹2,200.

The point is not to predict prices.

It is simply to recognise that a fixed monetary threshold does not automatically retain the same purchasing relevance over time.

 

Act III — One Small Automatic Step

So, instead of waiting for another policy discussion every year, could the threshold itself have a simple pre-defined movement?

15 October 2026
₹2,000

15 October 2027
₹2,100

15 October 2028
₹2,200

And continue with the same ₹100 annual increase.

No new payment rail.

No new customer process.

No complicated technology.

Just one number, moving predictably once a year.

The Whiteboard

IF THE BASKET GROWS,
CAN THE FREE SLAB GROW TOO?

Why It Helps

A pre-defined annual increase would make the ₹2,000 free slab predictable rather than periodically revisited.

It could:

  • keep the free slab more relevant to everyday household baskets as prices change;
  • give merchants and customers a known threshold for the coming year;
  • avoid the need for a fresh threshold discussion every year;
  • retain the simplicity of the existing framework — one threshold, one automatic annual adjustment.

The proposal does not suggest changing the ₹2,000 threshold immediately.

It simply asks whether the framework could say:

₹2,000 in Year 1.
₹2,100 in Year 2.
₹2,200 in Year 3.
And so on.

A small annual adjustment could keep a small-value protection designed for today's basket relevant to tomorrow's basket.

 

Nothing More — Nothing Less

This is not a proposal to remove MDR.

It is not a proposal to change the 0.40% rate.

It is not a proposal to redesign UPI.

It is simply one question about the ₹2,000 free slab:

Can the threshold itself grow by ₹100 every year?

The framework already provides the number.

This Citizen Observation only asks whether that number should be allowed to move with time.

Closing Thought

₹2,000 is not just a number.

For a customer, it can represent a basket of rice, dal, cooking oil, vegetables, milk and other everyday essentials.

Today, that basket may fit below the line.

Tomorrow, it may not.

So perhaps the question is not whether the ₹2,000 free slab is appropriate today.

Perhaps it is:

Can we make sure the free slab remains relevant tomorrow?

₹2,000 today.
₹2,100 next year.
₹2,200 the year after.

One small, automatic step every year.

Because a threshold designed for everyday payments should have a way to grow with everyday life, without much stress.

 

 

April 11 Digital Transactions Day

April 11 -  UPI Beta Launch

UPI has made everyday payments increasingly simple.

From a ₹100 purchase to a ₹2,000 household basket, the convenience is in the ability to pay digitally without thinking about the payment itself.

As the UPI ecosystem evolves, the framework around those everyday payments will evolve too.

This Citizen Observation is one small suggestion within that journey:

If the everyday basket can grow with time,
perhaps the ₹2,000 free slab can grow with it.

₹2,000 → ₹2,100 → ₹2,200 → …

A predictable annual movement.

Nothing More — Nothing Less.


Disclaimer

This is a Citizen Observation, not a representation of NPCI, RBI, any bank, UPI app, merchant, or other institution.

The suggestion is limited to the annual ₹100 increase in the ₹2,000 threshold and does not comment on the other provisions of the UPI MDR framework. Let the threshold grow, without much stress.

The views expressed are personal and intended to encourage constructive citizen dialogue.

 

The Joy of Digital Transactions

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru
Advocating Digital Transactions Day (April 11)

Author’s Blogs

https://prashantrandomthoughts.blogspot.com
https://prashantnepayments.blogspot.com
https://innovationinbanking.blogspot.com











Thursday, August 6, 2026

Citizen Observation 20 of 777 | RBI Responsible Business Conduct Directions | One Technology-Based Mechanism. | Millions of Borrowers. | One Stronger Layer of Technology Trust.

 Published August 06, 2026

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru

Just hot off the press

What If One Carefully Written Sentence Quietly Strengthened Digital Trust?

A Citizen Observation Inspired by the Reserve Bank of India's Amendment Directions on Conduct of Regulated Entities in Recovery of Loans and Engagement of Recovery Agents.

 

Please note the mobile device of a borrower is defined as mobile phone, tablet and laptop.

 

The Starting Point

Dear Reserve Bank of India Team,

At the outset, appreciation for issuing the final Amendment Directions on Conduct of Regulated Entities in Recovery of Loans and Engagement of Recovery Agents, after considering stakeholder feedback received on the revised draft Directions.

Effective from January 1, 2027, these Directions strengthen responsible recovery practices across India's regulated lending ecosystem—from Commercial Banks and Small Finance Banks to Local Area Banks, Regional Rural Banks, Urban and Rural Co-operative Banks, All India Financial Institutions, Non-Banking Financial Companies and Housing Finance Companies.

The framework covers multiple aspects of responsible business conduct, including fair treatment of borrowers, conduct of lender employees and recovery agents, due diligence, training, technology-based recovery mechanisms and several other important safeguards.

While reading this comprehensive framework...

one particular sentence quietly stayed with me.

Not because it was the longest.

Not because it introduced the biggest policy change.

But because it quietly strengthened something that every digital ecosystem ultimately depends upon Trust.

 

Act I | One Device

A financed mobile phone, tablet or a laptop is no longer merely a device.

For millions of borrowers...

it is also a workplace.

A classroom.

A banking channel.

A digital identity.

Sometimes...

even a livelihood.

The device may fit inside a pocket.

Its importance certainly does not.

Today...

a mobile device often carries far more than applications.

It carries conversations.

Memories.

Financial access.

Professional responsibilities.

Personal identities.

When technology becomes such an important part of everyday life...

confidence in that technology quietly becomes equally important.

 

Act II | One Quiet Sentence

Hundreds of paragraphs.

Thousands of carefully chosen words.

Yet...

one sentence quietly caught my attention.

Paragraph 454S(4).

"The bank and / or the third-party service provider shall obtain certification for its technology-based mechanism from the Original Equipment Manufacturer (OEM) of the mobile device and / or the Operating System platform, if provided."

For many readers...

this may simply appear to be another technical requirement.

Perhaps...

it is much more than that.

Perhaps it quietly adds another layer of technology trust.

Not by changing the borrower.

Not by changing the mobile device.

But by recognising that confidence in technology also deserves thoughtful safeguards.

Sometimes...

the most reassuring sentence inside a regulatory framework is not the one that receives the most attention.

It is the one that quietly strengthens confidence in how technology itself is expected to operate.

 

The Journey Continues...

The story, however, is not merely about one paragraph.

It is about something much larger.

How trust is quietly built...

one carefully written safeguard at a time.

 

Act III | Trust Is Often Invisible

Technology is easiest to notice...

when something goes wrong.

Trust is hardest to notice...

when everything works exactly as expected.

Most borrowers may never read Paragraph 454S(4).

Most borrowers never need to.

They simply expect technology to function responsibly.

That expectation is not accidental.

It is quietly supported by countless safeguards that rarely become headlines.

Some are legal.

Some are operational.

Some are technological.

Together...

they strengthen confidence.

Sometimes...

public trust is not built through one major announcement.

It is strengthened through carefully considered details.

One thoughtfully written paragraph.

One carefully designed safeguard.

One stronger layer of technology trust.

Perhaps...

that is why this paragraph stayed with me.

It does not change the borrower.

It does not change the financed mobile device.

It quietly strengthens confidence in the technology that supports responsible recovery.

 

Act IV | The Observation

Citizen Observation 777 is often associated with suggesting new ideas.

Sometimes...

it also pauses to recognise a thoughtful idea that has already become part of public policy.

This is one such moment.

Citizen Observation 777 welcomes the inclusion of certification by the Original Equipment Manufacturer (OEM) of the mobile device and / or the Operating System platform as an important layer of technology trust within the Reserve Bank of India's final Directions.

This observation does not seek to interpret certification standards.

It does not seek to comment upon implementation methodology.

It does not recommend technical specifications.

Those decisions belong entirely to the Reserve Bank of India, regulated entities, Original Equipment Manufacturers, Operating System platform providers, technology service providers and the concerned domain experts.

Citizen Observation 777 simply pauses to recognise one carefully designed layer of technology trust within a much broader regulatory framework.

 

 

The First Line on the Whiteboard

OEM / Operating System Certification

↓

One Stronger Layer of Technology Trust

How that line is completed belongs entirely to the Reserve Bank of India, regulated entities, Original Equipment Manufacturers, Operating System platform providers, technology service providers and the concerned domain experts.

 

The Journey Continues...

Every comprehensive regulatory framework contains many important provisions.

Some protect borrowers.

Some strengthen institutional accountability.

Some improve operational discipline.

Some quietly strengthen confidence in technology.

Perhaps...

Paragraph 454S(4) is one such provision.

Not because it seeks attention.

But because it quietly contributes to something every digital ecosystem depends upon.

Trust.


 

Act V | January 1, 2027

January 1, 2027 arrives.

No countdown.

No ribbon-cutting ceremony.

No television debates.

For most borrowers...

it begins like any other day.

Yet...

quietly...

another layer of technology trust becomes part of India's responsible lending framework.

Millions of borrowers may never notice.

Perhaps...

they do not need to.

The strongest safeguards are often the quietest ones.

They work silently in the background.

Public confidence becomes their most visible outcome.

Sometimes...

the true success of a regulation is not measured by the headlines it creates.

It is measured by the confidence it quietly builds.

 

Citizen Observation

Citizen Observation 777 is not only about suggesting better ideas.

It is equally about recognising thoughtful ideas when they become part of public policy.

This observation does not recommend a new regulation.

It simply recognises one carefully designed layer of technology trust within a much broader regulatory framework.

Because trust rarely grows through one grand announcement.

Sometimes...

it grows...

one carefully written sentence at a time.

 

Disclaimer

This is a citizen observation inspired by the Reserve Bank of India's Amendment Directions on Conduct of Regulated Entities in Recovery of Loans and Engagement of Recovery Agents.

The observation specifically refers to Paragraph 454S(4) and appreciates one aspect of the final Directions.

The interpretation of the regulatory provisions, certification processes, implementation methodology, technical standards, supervisory expectations and operational framework are entirely for the Reserve Bank of India, regulated entities, Original Equipment Manufacturers, Operating System platform providers, technology service providers and the concerned domain experts.

Citizen Observation 777 draws only the first line on the whiteboard.

How that line is completed belongs entirely to the concerned domain experts.

The only Joy is Digital Transactions Day.


The April 11 – Digital Transactions Day Philosophy

Digital transformation is often associated with innovation.

Sometimes...

its strongest foundation is trust.

Trust is the invisible infrastructure of Digital Transactions.

It grows through thoughtful regulation.

Responsible implementation.

Clear accountability.

And carefully designed safeguards.

Perhaps...

today's amendment reminds us that Digital Transactions become stronger not only through innovation...

but also through trust.

Please note that Digital Payments are a subset of Digital Transactions.

Looking forward for the Go Live


The Joy of Digital Transactions

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru
Advocating Digital Transactions Day (April 11)

Author’s Blogs

https://prashantrandomthoughts.blogspot.com
https://prashantnepayments.blogspot.com
https://innovationinbanking.blogspot.com

 

Additional Reading:

https://www.rbi.org.in/Scripts/BS_PressReleaseDisplay.aspx?prid=63305

 

 



Monday, July 27, 2026

Citizen Observation 11 of 777 | RBI | One Consultation. | One Deadline. | One Better Participation Journey

 The Deadline Is the Last Date. Does It Have to Be Our Submission Date?

The Regulator Creates Time to Participate. Perhaps We Should Create Time to Participate Well.

Published: 27 July 2026

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru


The Starting Point

Dear Reserve Bank of India Team,

At the outset, appreciation for a regulatory practice that deserves recognition.

Before many regulatory proposals become final, RBI places drafts in the public domain and invites comments from stakeholders and members of the public.

On June 24, 2026, RBI invited comments on the draft Guidance on Regulatory Principles for Model Risk Management, 2026.

The last date was July 24, 2026, with a digital submission route through Connect 2 Regulate.

My experience produced an observation.

This time, however, it is not primarily for the institution.

It is for the participant on the other side of the consultation.

 

Act I | The Invitation

June 24, 2026.

A draft appears on the RBI website.

Model Risk Management.

Governance.

Artificial Intelligence and Machine Learning.

Oversight. Controls. Risk.

Technical subjects.

But alongside them is something remarkably simple:

An invitation to comment.

The regulator has opened the door before the regulatory journey is complete.

Stakeholders can study.

Experts can suggest.

Institutions can respond.

Citizens can participate.

And there is a date:

July 24, 2026.

A month can look like plenty of time.

Until it becomes...

the last day.

 

Act II | The Final Click

The draft is downloaded.

Read.

Re-read.

Paragraphs are marked.

Suggestions are drafted, rewritten and checked.

Eventually, the feedback is ready.

Only one step remains.

Submit.

In my case, that step came on July 24 itself.

I opened Connect 2 Regulate.

Instead of the expected submission page:

“You are not authorized to view this page. Please contact concerned Support Team.”

Suddenly, a date that looked like available time...

became very little time.

Fortunately, RBI had also provided an email address for comments and attachments.

The feedback was submitted through that route.

The submission went out.

And a lesson came back.

 

Act III | The Observation Turns Around

It would be easy to make the portal error the Citizen Observation.

But there is another side.

The consultation opened on June 24.

The deadline was July 24.

I chose to complete my submission on the last day.

So perhaps the first question should not be:

What could the institution have done differently?

Perhaps, this time:

What could I have done differently?

The answer is simple.

Submitted earlier.

 

Act IV | One Citizen Suggestion

For anyone participating in a public consultation, could we adopt one simple personal discipline?

Treat T-1 as our target.

Where circumstances permit, aim to submit at least one working day before the official deadline.

The official deadline remains unchanged.

Our personal target simply moves earlier.

That small margin can help when a portal behaves unexpectedly, an attachment needs correction, a final review takes longer, or something unforeseen happens.

The regulator gives us a consultation window.

Perhaps we should leave ourselves a little window within that window.

The First Line on the Whiteboard

Citizen Observation 777 draws only the first line on the whiteboard.

Sometimes that first line is for an institution.

Sometimes it is for the citizen looking back from the other side of the whiteboard.

CO11 is one of those occasions.

The institution invited participation.

My learning is to participate a little earlier next time.

 

Act V | Before the Circular Goes Live

There is something valuable about being invited to comment before a regulatory proposal reaches its final form.

The regulator drafts.

The consultation opens.

Stakeholders respond.

Inputs are considered.

Eventually, the regulatory journey moves forward.

No participant should assume that a suggestion will necessarily be accepted.

That is not the point.

The opportunity to contribute before finalisation is itself valuable.

And when an institution creates that opportunity...

perhaps our responsibility is not merely to participate.

It is to give our participation the time it deserves.

 

Citizen Observation

CO11 leaves me with one simple lesson:

A deadline is the last date to submit.
It need not become the day we choose to submit.

For future public consultations, my starting point will be:

Official Deadline: T

Personal Target: T-1 Working Day

Not because the institution asks for it.

Because a little margin can protect the effort invested before the final click.

The regulator creates time for us to participate.

Perhaps we should create time for ourselves to participate well.

 

Disclaimer

Citizen Observation 777 is built on a simple belief: every meaningful improvement begins with someone willing to draw the first line on a blank whiteboard.

These observations are intended to start conversations, not conclude them.

CO11 reflects a personal submission experience and the learning drawn from it. The design and operation of regulatory consultation channels rightly remain with the Reserve Bank of India and its relevant teams.

 

The April 11 – Digital Transactions Day Philosophy

Citizen Observation 777 believes that thoughtful digital journeys matter across different forms of citizen participation.

A consultation is published digitally.

A draft is accessed digitally.

Feedback is prepared and submitted digitally.

The experience reminds us that good digital journeys work best when institutions create opportunities and citizens participate thoughtfully.

That philosophy also inspires the proposal to recognise April 11 as Digital Transactions Day — UPI Birthday.

Digital Payments is a sub-set of Digital Transactions.

The universe of Digital Transactions covers Digital Payments too.


The Joy of Digital Transactions

Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru
Advocating Digital Transactions Day (April 11)

Author’s Blogs

https://prashantrandomthoughts.blogspot.com
https://prashantnepayments.blogspot.com
https://innovationinbanking.blogspot.com



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All efforts have been made to make this information as accurate as possible, N Prashant will not be responsible for any loss to any person caused by inaccuracy in the information available on this Website. Relevent Official Gazettes Communications may be consulted for an accurate information. Any discrepancy found may be brought to the notice of N Prashant