Deadline approaching: Mandatory EMI, Autopay and credit limit management in Unified Payments Interface applications to go live by 31st May, 2024

Members of Unified Payments Interface (“UPI”) have only till 31st May, 2024 to implement EMI facility, establish Autopay and set up credit limit management options in their UPI applications (“UPI App”). Earlier this year, in March,[1] the National Payments Corporation of India (“NPCI”) notified these three (3) new facilities, with a directive for their incorporation into UPI applications by 31st May, 2024. With these additions, UPI platforms will be able to offer EMI options, facilitate Autopay for settlement of outstanding credit card bills and provide customers with the ability to accept or apply for credit limit enhancements. The introduction of AutoPay option in UPI underscores ongoing innovation in the digital payments sector and was one of the key recommendations from the Reserve Bank of India’s Committee on Deepening of Digital Payment.

By 31st May, 2024, all UPI members are required to mandatorily introduce the following features in their UPI App:

 

New Feature

 

Changes to be brought in the UPI Application

EMI Facility

  • Enable option for users to apply for EMI facility on linked credit accounts through the UPI App

  • Consider/ use the UPI PIN as the user consent for accepting relevant terms and conditions.

  • Allow users to:

    1. convert past purchases made using a credit account into EMIs through transaction history in the UPI App.
    2. convert purchases into EMI at the time of the transaction.
  • Display existing EMIs in the appropriate section of the UPI App.

  • Prevent users from modifying / deleting the EMIs, except for foreclosure.

Credit Account bill/ Instalment Payment

  • Allow users to pay overdue credit card bills and credit line instalments for themselves and other users via one-time payments or UPI AutoPay.

  • Provide users with access to details of linked credit cards’ outstanding bills and credit line instalments, including minimum and total amounts due, total amount due etc.

Credit Limit management

  • Offer customers the option to enhance their credit limit either for a specific period or in a generic manner with UPI Pin serving as explicit consent from the customer.

  • Ensure customers can use this feature for large purchases, emergencies, ad-hoc expenses, festivals, family events, etc.

To implement these new changes, banks and credit card issuers (Members on the Unified Payment Interface) are required to prepare internally on integrating these functionalities, starting from enabling EMI feature for customers, providing them option to convert their purchases to instalments and providing users access to detailed information about linked credit cards’ outstanding bills and credit line instalments (including minimum and total amounts due), and displaying relevant EMI information in appropriate places within the UPI Applications have to ensure that their applications are compliant with these features by end of May this year.

UPI has emerged as a transformative force in India’s journey towards a digital future. India has seen rapid strides in the digital payment space in recent times, with National Payments Corporation of India issuing multiple directives for UPI members and introducing new changes in the UPI ecosystem. NPCI has further implemented innovative changes such as “UPI Tap and Pay” option, UPI Lite, “Hello UPI” feature (voice-based command service for customers), interoperability and acceptance of UPI QR codes for digital rupee transactions, and enhancement of per transaction value for UPI Lite (Online and Offline) to Rs. 500/- etc.

Every change introduced in the UPI ecosystem brings with it an increased compliance obligation, frequent adaptation and enhancement of UPI applications, higher compliance costs and the need to establish processes to monitor compliance, thereby avoiding penal consequences.

How Komrisk will help you remain compliant?

In this dynamic Indian regulatory environment, Komrisk, our Compliance management software/tool, offers a comprehensive solution for enterprise-level regulatory compliance management solution. It integrates the efforts of business, marketing, finance, technology, and legal teams into a unified platform, promoting collaboration among diverse stakeholders to maintain compliance across all levels of the organization. Additionally, it functions as a repository of relevant compliance obligations in the form of simple actionables, along with corresponding penalties for non-compliance.

With the ability to upload tangible evidence of compliances, Komrisk, which works on a maker-checker concept, validates the completion of compliance tasks and features a flexible escalation mechanism spanning up to ten levels ensuring that non-compliance / late-compliance issues are addressed promptly. It also offers real-time dashboard reports, empowering senior management with insights to enhance operational efficiency, promote transparency, and monitor compliance status in real-time. By evaluating potential risks associated with pending compliances across all entities, operating units, and departments, Komrisk facilitates informed decision-making and provides a panoramic view of the organization’s compliance landscape.

[1] https://www.npci.org.in/PDF/npci/upi/circular/2024/UPI-OC-194-FY-23-24-Introduction-of-new-features-for-Credit-Accounts.pdf

Written by: Bitasta Ganguly

Co-authored by: Abhishek Roy

Disclaimer

This content is intended for informational purposes only and does not constitute a legal opinion. Despite our efforts to maintain accuracy, we do not make representations, warranties or undertakings regarding the quality, completeness or reliability of the content. Readers are encouraged to seek legal counsel prior to acting upon any of the information provided herein. This content, including the design, text, graphics, their selection and arrangement, is Copyright 2024, Lexplosion Solutions Private Limited or its licensors. ALL RIGHTS RESERVED, and all moral rights are asserted and reserved.

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