e-Mandate

The RBI's e-Mandate framework fundamentally changed how subscription and recurring payments work for merchants operating in India. Understanding the framework is essential for any SaaS, streaming, or lending platform collecting recurring payments from Indian customers.

The RBI Framework

Before October 2021, recurring card payments in India worked like most markets: a merchant stored card credentials and debited them on schedule. The RBI determined this created unacceptable fraud risk and consumer protection gaps, and mandated a new registration and execution flow.

Registration: The first debit (or the mandate registration itself) must be authenticated by the customer via AFA — typically OTP to the registered mobile number. The customer sets a maximum debit amount and frequency.

Pre-debit notification: The issuer generally sends the customer a notification at least 24 hours before a recurring debit under the RBI framework. The RBI's August 2024 circular exempts qualifying FASTag and National Common Mobility Card auto-replenishments from that notification requirement. Merchants still need a provider flow that supplies the required mandate and debit information.

Execution: Subsequent debits within the mandate terms can proceed without a fresh authentication step up to the applicable threshold. The RBI raised it from ₹15,000 to ₹1 lakh for mutual fund subscriptions, insurance premiums and credit card bill payments in December 2023. Other categories retain the lower threshold. A provider may impose additional limits or controls.

Impact on Merchants

The framework initially caused significant subscription payment failures as merchants scrambled to implement compliant flows. Key operational requirements:

• Integration with a bank or PSP that supports e-Mandate registration (not all do)
• Coordination with the issuer/provider's pre-debit notification process where required
• Retry logic for failed mandates and customer re-registration flows
• Separate handling for UPI AutoPay vs. card e-Mandate (different technical paths)

UPI AutoPay

UPI AutoPay is India's parallel recurring payment mechanism for UPI-linked accounts. It operates under a similar mandate framework but through the UPI rails rather than card networks. For merchants with significant Indian consumer volume, supporting both card e-Mandate and UPI AutoPay is typically necessary to capture the full addressable market.