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3Digital Payments Ecosystem DIGITAL PAYMENTS IN INDIA ABOUT SMAHI FOUNDATION OF POLICY AND RESEARCH Smahi Foundation of Policy and Research is a non-profit organization based in Bengaluru. The word Smahi stands for progress. Smahi Foundation of Policy and Research (Smahi) works towards forward-looking policy making and harmonization of stakeholder views on issues of public policy to lead India towards progress. We focus on technology-led solutions to spur creation of stronger public digital infrastructure. AUTHORS RITU BHANDARI Ritu Bhandari is a Chartered Accountant by Head of Research, Smahi profession, with extensive experience working in the banking industry. AASHISH Aashish Chandorkar is an engineer and MBA, CHANDORKAR with global experience running management Director, Smahi consulting businesses. NIMISH JOSHI Nimish Joshi is an engineer and MBA, with Director, Smahi experience in conceptualizing, funding and scaling technology businesses. https://twitter.com/SmahiFoundation © Smahi Foundation of Policy and Research, 2020. All Rights Reserved. No part of this report may be copied, reproduced, distributed or transmitted in any form or by any means, including photocopying, recording or other electronic or mechanical methods, without the prior written permission of the Smahi Foundation for Policy and Research. Contact Us: +91 97300 13314 | [email protected] 2 DIGITAL PAYMENTS IN INDIA June 2021 1 DIGITAL PAYMENTS IN INDIA CONTENTS 04 05 DEFINITIONS EXECUTIVE SUMMARY 06 10 1. BACKGROUND 2. EVOLUTION OF DIGITAL Industry Size 6 PAYMENTS IN INDIA India Stack 7 RuPay 10 JAM Trinity 7 Unified Payment Interface (UPI) 11 Shift away from Cash, still Cash is King 8 Other Innovative Payment Solutions- Wallets, 13 NACH, APBS, FASTag, BBPS, NCMC, AePS 15 21 3. DIGITAL PAYMENTS 4. REGULATORY INITIATIVES TO ECOSYSTEM FACILITATE DIGITAL PAYMENTS Third-Party Application Providers (TPAPs) 15 Increase in the limit for contactless card 21 transaction from Rs 2,000 to Rs 5,000 • NPCI stipulates cap of 30 per cent for TPAs in UPI payments Interoperability 22 • Whatsapp Pay- potential growth horse given Regulatory Sandbox – first cohort of testing 22 NUE framework Offline Retail Payments • Jio’s strategic partnership with Facebook and Google Payments Infrastructure Development Fund 23 (PIDF) Payment Aggregators (PAs) and Payment 18 23 Gateways (PGs) Others • Licensing requirement E-commerce companies 18 Convergence between commerce, payment and 19 financial services Payment System Operators (PSOs) 19 • National Payments Corporation of India (NPCI) • New Umbrella Entity (NUE) 2 DIGITAL PAYMENTS IN INDIA 25 31 5. DRAFT PERSONAL DATA 6. FUTURE TRENDS IN PROTECTION BILL, 2019 (PDP) PAYMENTS Data localisation 25 New Use cases of UPI, Offline retail payments, 31 Contactless digitization of Transit Government to have unhindered access to citizen’s 28 data Mass digitization of small businesses 32 Consent to be specific, capable of being withdrawn 29 Open Banking to drive lending to MSME 32 Principle of Purpose/ Use limitation; Data 29 • Account Aggregator Framework (AA) minimization/ Collection limitation; • OCEN PortabilityApproaches across key Jurisdictions 30 Super Apps 35 Mass adoption of Buy Now Pay Later (BNPL) 36 Internationalization of Aadhar, UPI and RuPay 37 Public Credit Registry (PCR) 37 AtmaNirbhar App Store 37 Digital Currency 38 Potential of Blockchain to unlock efficiency in 38 cross-border digital payments • Cross Border transactions- Interbank Information Network (INN) 40 48 7. KEY CONCERNS 8. SMAHI VIEW AND RECOMMENDATION Outages in UPI; banks going slow on RuPay 40 Restoration of MDR on transactions vide UPI and 50 debit cards RuPay to promote acceptance Cyber Security 41 Regulation of Online Predatory Loan Apps/ Digital 51 lending • Security Measures taken by RBI Strengthen the Account Aggregator (AA) Framework 53 Proliferation of predatory instant loan apps 43 Cyber Security • P2P Lending 54 Ease of KYC Compliance for Banks and NBFCs 55 Impending Delinquency/ Over-leverage in Lending 45 60 63 ANNEXURE 1 ANNEXURE 2 The Next Frontier; Financial Services Regulatory Sandbox under first cohort of Retail Payments 3 DIGITAL PAYMENTS IN INDIA DEFINITIONS ACCOUNT Account Aggregator (AA) is a financial entity that is in the business of retrieving or AGGREGATOR (AA) collecting information of its customers pertaining to financial assets and consolidating, organizing and presenting such information to the customer or any other person as per the instructions of the customer. PERSONAL DATA Personal data is data which pertains to characteristics, traits or attributes of identity, which can be used to identify an individual. CRITICAL Critical personal data is as notified by the government from time to time. PERSONAL DATA SENSITIVE PERSONAL Sensitive Personal Data amongst other information includes financial data (including DATA (SDP) payment data), biometric data, health data, official identifiers, caste, religious or political beliefs. DATA PRINCIPAL Data Principal means the natural person to whom the personal data relates to. DATA FIDUCIARY A Data Fiduciary means any person, including the State, entity or any individual who alone or in conjunction with others determines the purpose and means of processing of personal data. Such processing will be subject to certain purpose, collection and storage limitations. PAYMENT PAs are entities that facilitate e-commerce sites and merchants to accept various payment AGGREGATOR (PA) instruments from the customers for completion of their payment obligations without the need for merchants to create a separate payment integration system of their own. PAs facilitate merchants to connect with acquirers. In the process, they receive payments from customers, pool and transfer them on to the merchants after a time period. PAYMENT PGs are entities that provide technology infrastructure to route and facilitate processing GATEWAYS (PG) of an online payment transaction without any involvement in handling of funds. PGs shall be considered as ‘technology providers’ or ‘outsourcing partners’ of banks or nonbanks, as the case may be. 4 DIGITAL PAYMENTS IN INDIA EXECUTIVE SUMMARY India has built an expansive, secure, efficient and account but getting easy access to credit, insurance scalable public digital infrastructure. The entry of and micro-investment products. Digital payments well-funded and aggressive has laid the premise for the digitization and cross- India Stack (Aadhar, UPI, technology-first companies selling of financial services such as Lending, e-KYC, e-signature among (erstwhile dominated by Insurance, Wealth Management etc. to monetize others), is paving the Banks) has made digital the data collected from the large user base. way for a massive world- payments ubiquitous in India leading ‘Digital Payments and laid a strong foundation Lending and coverage to self-employed retail and Revolution’. for digitization and cross- MSME is an issue, primarily due to the presence selling of other financial of a large informal sector, that banks are not able services and products. Select regulatory unlocks to assess and underwrite due to volatile income can further incentivize innovation among fin-tech or lend and collect due to high operating cost. players driving accelerated digitization of financial What is needed to plug the funding gap of self- services and helping greater financial inclusion. employed retail and MSMEs is to address the information asymmetry that impedes the access Cash is king, but Digital is divine. NPCI has to credit, for which we need to focus on digital played a pivotal role as infrastructure development. Open Banking and While India continues to have India continues to innovate Account Aggregator framework can digitise a cash bias, macro-events with contactless, offline data aggregation, assist in risk assessment and such as demonetization payments and new use cases credit monitoring, and thereby enable flow-based in 2016 and the current of UPI. With interoperability, lending. Higher digitization, leading to higher Covid-19 pandemic, have the cornerstone of RBI’s formalization, higher financialization (savings) and shifted consumer preference regulatory approach, it has democratization of data and lending would lead to towards digital payments in a been ensured that payment easier, faster and higher lending. big way. solutions can be used across the system participants. The draft Personal Data Protection Bill is There is a blurring of industry lines as e-commerce balanced in comparison to EU GDPR, but gives the companies seek to offer a gamut of financial services Indian government more leeway than EU. While and financial services companies integrate in a big way any data transaction is consensual, the inclusion with retail commerce. of non-personal data giving unhindered access to Government and data localisation may bother However, abolition of MDR on UPI has the Big Tech for whom India is the largest internet disincentivised the banks in investing in market outside the USA, since China has not given technological upgrades in the face of exponential them entry. growth in throughputs and thereby increased transaction failures. Digitization of payments will help transition the huge informal sector in India to a formal economy Financial inclusion would be incomplete without and generate higher tax revenues. With only 100 the last mile inclusion of the weaker sections and million active users for digital payments on board, low-income groups in not only opening a bank the journey has just begun. 5 DIGITAL PAYMENTS
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