CARD91 flags merchant-data hurdles in any selective UPI MDR rollout
CARD91 says any selective UPI merchant discount rate framework would require verified merchant identities, accurate classification, continuous monitoring and clear redressal rules. No immediate MDR charge has been announced; any change remains subject to government, RBI and NPCI guidelines.
What happened
CARD91 says a potential selective UPI MDR framework will require verified merchant identities, accurate classification, ongoing monitoring and transparent
Key facts
- 23.66 billion UPI transactions
- ₹29.88 lakh crore transaction value
- July 2026
- July 2025
- Taxation and Other Laws (Amendment) Bill, 2026
Why this matters
Evaluate partnerships or acquisitions in merchant verification, classification and transaction-monitoring capabilities, which could become strategic assets if selective UPI pricing advances.
What to watch
- Finance Ministry, RBI or NPCI consultation language on UPI sustainability, payment-system funding or merchant discount rate differentiation.
- Any proposal defining eligible cohorts such as large enterprises, high-turnover merchants, specific MCCs, premium services or high-value UPI transactions.
- NPCI circulars requiring stronger merchant onboarding, QR attribution, beneficiary verification or merchant-category reporting.
- Budget announcements or changes in incentives/subsidies for UPI acquiring infrastructure and small-merchant acceptance.
- Acquirer requests for GSTIN, PAN, turnover, outlet-level or beneficial-owner data from existing UPI merchants.
- Rising enforcement actions involving merchant-category misrepresentation, QR-code fraud, mule accounts or subsidy leakage.
- Movement in merchant-acquisition pricing, where PSPs/acquirers begin charging separately for analytics, verification, settlement or premium acceptance tools.
- Build a merchant-identity graph linking UPI IDs, bank accounts, GSTINs, PANs, outlet locations, MCC-like category labels and beneficial-owner records.
- Audit merchant-category accuracy and create exception workflows for mixed-use, informal, marketplace and aggregator-led merchants.
- Develop continuous monitoring for QR-code misuse, account reassignment, transaction-pattern anomalies and merchant-size misclassification.
- Prepare configurable pricing, settlement and reconciliation systems that can apply rules by merchant type, transaction value, geography or payment use case.
- Create merchant redressal and appeals processes for classification disputes, fee disputes, blocked accounts and incorrect risk flags.
- Track whether acquirers and fintechs begin marketing merchant-verification, compliance-data or selective-pricing capabilities ahead of formal policy.