Published 17 th September 2026
Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru
https://in.linkedin.com/in/prashantnayakanti
1. The INTRO
A policy framework can affect different stakeholders in
different ways.
When a stakeholder identifies a concern, raises it with the
appropriate authority and receives a response, that becomes part of the policy
conversation.
Stockbrokers have raised concerns. SEBI has said it will
examine those concerns.
But this raises a broader question:
If the concerns of brokers can reach the regulator, can the
concerns of the common citizen also reach the policy table?
This Citizen Observation is not about questioning whether
brokers should be heard.
They should.
It is about asking whether the common citizen should also have
a visible avenue to place a measurable policy suggestion before the
decision-makers.
And this time, the suggestion is not merely a question.
It comes with a number.
2. THE TRIGGER
The immediate trigger for CO45 is the reported response of
SEBI Chairman Tuhin Kanta Pandey to concerns raised by stockbrokers regarding
the new UPI MDR framework.
Pandey said that SEBI would examine the issues raised by
brokers and look at how they could be eased.
The significance for this Citizen Observation is not whether
the broker concerns are ultimately accepted.
The significance is the policy-feedback mechanism:
Concern raised →
Regulator responds → Issue gets examined.
That is an important part of how policy can evolve.
But it also provides an opportunity to ask a citizen-facing
question:
What happens when the common citizen has a concern?
The UPI MDR framework is not merely a technical payment-system
change. The structure of thresholds and charges can influence how different
participants experience the digital-payment ecosystem.
So, alongside stakeholder concerns, can there also be room for
a simple, measurable citizen suggestion?
CO45 attempts to place one on the table.
3. PROSPECTIVE AUDIENCE
This observation is deliberately addressed to three audiences:
PMO — Decision Maker
The primary audience for placing the citizen proposal at the
policy level.
SEBI — Interested Party
SEBI is directly relevant to this conversation because its
Chairman has publicly responded to concerns raised by stockbrokers regarding
UPI MDR.
Common Citizen — Most Affected Party
The citizen is not merely an observer of the policy
conversation.
The citizen is one of the participants whose everyday
digital-payment behaviour is shaped by the framework.
Prospective Audience: PMO | SEBI | The Common Citizen
And the central question remains:
SEBI hears the brokers.
Who will hear the common citizen?
4. ABOUT THE ISSUE
The new UPI MDR framework introduces differentiated treatment
for certain Person-to-Merchant (P2M) transactions.
Under the framework, specified P2M UPI transactions up to
₹2,000 remain outside MDR, while transactions above ₹2,000 attract MDR
according to the applicable category. The framework is scheduled to take effect
from 15 October 2026.
The ₹2,000 threshold therefore becomes an important reference
point.
But a threshold created at one point in time does not
necessarily remain equally relevant as transaction values change.
This is where CO44 raised the first citizen question:
IF THE BASKET GROWS, CAN THE FREE SLAB GROW TOO?
CO44 proposed:
₹2,000 → ₹2,100 → ₹2,200 → …
CO45 takes that thought one step further.
Rather than beginning the annual progression from ₹2,000,
could the threshold first be reset to ₹2,500 when the new framework comes into
effect?
And thereafter:
₹2,500 → ₹2,600 → ₹2,700 → ₹2,800 → …
with an annual increase of ₹100 every October.
The proposal is deliberately simple.
It does not attempt to redesign the entire UPI MDR framework.
It asks whether the starting point itself can be reconsidered,
followed by a predictable annual adjustment.
CO44 asked whether the slab can grow.
CO45 asks whether the slab should first be reset — and then allowed to grow.
This is not presented as the only possible answer.
It is one measurable option placed before the decision-makers
for consideration.
5. ONE MEASURABLE SUGGESTION
Reset the Slab. Then Let It Grow.
New Delhi. September 2026.
A concern has been placed on the table.
Stockbrokers have raised concerns about UPI MDR.
At the policy table, SEBI Chairman Tuhin Kanta Pandey has said
that SEBI will examine those concerns and see how they can be eased.
Now, imagine another voice entering that same policy
conversation.
Not a broker.
Not an industry association.
A common citizen.
And instead of arriving with a complaint, the citizen arrives
with one number, one date and one simple mechanism.
₹2,500.
The citizen suggestion:
Reset the UPI MDR free slab from ₹2,000 to ₹2,500 from October
2026.
Then let it move predictably:
₹2,500 → ₹2,600 → ₹2,700 → ₹2,800 → ₹2,900 → …
with ₹100 added every October.
|
October |
Proposed Slab |
|
2026 |
₹2,500 |
|
2027 |
₹2,600 |
|
2028 |
₹2,700 |
|
2029 |
₹2,800 |
|
2030 |
₹2,900 |
|
Thereafter |
+₹100 every October |
Why this suggestion?
Because the citizen is not asking for an open-ended exemption
or a complicated new mechanism.
The proposal has:
A number — ₹2,500
A date — October 2026
An increment — ₹100
A frequency — every October
The annual increment can be reviewed by the appropriate
authorities if circumstances warrant a different approach.
So the proposal is not presented as the only answer.
It is one concrete option placed before the decision-makers —
to accept, modify or reject.
And here is the citizen's moment at the table:
The brokers have placed their concern.
SEBI has said it will hear them.
Here is the common citizen's proposal.
₹2,500 now.
₹100 more every October.
One number. One date. One predictable path.
6. READY-TO-USE SOLUTION
RESET → INDEX → REVIEW
RESET
₹2,000 → ₹2,500
from October 2026
INDEX
₹2,500 → ₹2,600 → ₹2,700 → ₹2,800 → ₹2,900 → …
+ ₹100 every October
REVIEW
The mechanism can be reviewed periodically by the appropriate
authorities and modified if circumstances warrant.
One simple mechanism. One measurable citizen option.
7. WHY IT HELPS
A predictable annual adjustment could provide:
Predictability — a clearly defined annual movement.
Transparency — the adjustment is visible rather than requiring
a fresh policy discussion each time.
Simplicity — one number, one annual increment and one review
mechanism.
Citizen participation — a general concern becomes a specific
policy option.
It does not assume that ₹2,500 or ₹100 is permanently correct.
It simply places a measurable option before the appropriate
decision-makers:
Consider it. Modify it. Or reject it.
But let the citizen proposal be heard.
8. CLOSING THOUGHT
SEBI HEARS THE BROKERS.
WHO WILL HEAR THE COMMON CITIZEN?
A stakeholder raised a concern.
The concern reached the regulator.
The regulator said it would examine the issue.
Now the common citizen places a different kind of concern on
the table — not merely a complaint, but a measurable suggestion.
₹2,500 from October 2026.
₹100 more every October thereafter.
If stakeholders can put their concerns on the table, can the
common citizen's concern have a seat at the same table?
9. THE WHITEBOARD
THE BROKERS BROUGHT A CONCERN.
THE CITIZEN BRINGS A NUMBER.
₹2,500 → ₹2,600 → ₹2,700 → ₹2,800 → …
+ ₹100 EVERY OCTOBER
10. DISCLAIMER
Citizen Observation 777 is intended to start conversations,
not conclude them.
This proposal is offered purely from a citizen's perspective
and may be accepted, modified, reviewed or rejected by the appropriate
authorities based on wider policy considerations.
A beginning has to be made, and this is the beginning.
11. APRIL 11 — DIGITAL TRANSACTIONS DAY
April 11 — Digital Transactions
Day
UPI began its beta journey on
April 11, 2016.
Digital payments are shaped not
only by transactions, but also by the rules and choices that govern them.
CO45 is one small citizen
suggestion in that continuing journey:
As there seem to be opportunities
for stakeholders to put forward their suggestions, this is one small step
towards that.
As of now, I am not sure what
shape this will take, but the prayer for the limit to be increased to ₹2,500/-
will continue.
Listen to the stakeholders. Hear
the citizen. Keep improving the system.
The guide for Citizen Observation
45 is Chapter 2, Verse 47 of the Bhagavad Gita, where Lord Krishna tells Arjuna
that you have a right to do your work, but you do not control the results.
The only Joy is —
The Joy of Digital Transactions
Advocating Digital Transactions
Day (April 11)
This version retains your
important distinction: the proposal is being pursued with effort, but without
claiming control over the outcome.
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
