Supreme Court plea challenges proposed MDR on UPI payments above ₹2,000
A PIL has challenged the Centre’s proposed merchant discount rate regime for UPI transactions above ₹2,000. The framework, due to take effect on October 15, 2026, proposes a 0.4% MDR, with exemptions for smaller payments and eligible small merchants.
What happened
A PIL in the Supreme Court challenges the Centre’s proposed MDR on merchant UPI payments above Rs 2,000, arguing inadequate safeguards and consultation. The
Key facts
- 0.4% MDR
- Rs 2,000 transaction threshold
- Rs 300 cap for transactions of Rs 75,000 and above
- Rs 5 flat MDR for specified sectors
- 0.02% MDR for capital-market transactions
- Rs 1 lakh monthly exemption threshold for small merchants
Why this matters
Payments, merchant-acquiring, and checkout-platform targets with enterprise UPI capabilities may gain strategic value if MDR is implemented, while retail acquirers should diligence exposure to higher transaction costs and exemption eligibility.
What to watch
- Supreme Court admission, notice to the Centre, interim stay, or hearing dates in the PIL.
- Final government notification detailing merchant eligibility, transaction aggregation rules, MDR payer, GST treatment, and enforcement mechanics.
- NPCI, RBI, Finance Ministry, and bank guidance on implementation and settlement flows.
- Merchant association responses and evidence of surcharge, minimum-ticket, or payment-steering experiments.
- UPI transaction mix changes around the ₹2,000 threshold, including potential ticket-splitting or migration to alternative rails.
- PSP and acquirer announcements of revised merchant pricing or subsidies ahead of October 15, 2026.
- Model UPI acceptance costs by average ticket size, merchant category, and share of transactions above ₹2,000; identify retailers with the greatest exposure.
- Prepare checkout steering and tender-routing tests, including incentives for lower-cost payment modes without degrading UPI conversion.
- Renegotiate PSP, acquirer, and payment-gateway contracts for MDR pass-through caps, blended pricing, and volume-linked rebates.
- Review pricing, loyalty, and promotional policies for potential restrictions on payment-method surcharges or customer steering.
- Track whether large marketplaces, fuel retailers, electronics chains, travel merchants, and department stores coordinate lobbying for threshold or rate changes.
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